Individual Case (CAS) - Discussion: 2025, Publication: 113rd ILC session (2025)

Labour Inspection Convention, 1947 (No. 81); Labour Inspection (Agriculture) Convention, 1969 (No. 129)

Written information provided by the Government

The Government has provided the following written information, as well as a copy of the 2024 labour inspection report (in Uzbek).

Upon reviewing the Committee’s request, the Ministry of Employment and Poverty Reduction notes that, pursuant to article 534 of the Labour Code, State control and supervision over compliance with labour legislation and occupational health and safety rules are exercised by the State Labour Inspectorate (SLI). As a structural subdivision of the Ministry, the SLI monitors and supervises employers’ compliance with labour laws, legislation on employment, compulsory insurance of employers’ civil liability, the rights of persons with disabilities, and other labour-related legal acts, health and safety regulations, and labour standards.

Chapter 33 of the Labour Code sets forth the procedure for monitoring and supervising compliance with labour legislation and occupational health and safety rules. Additionally, article 22 of the Law on the Prosecutor’s Office stipulates that, in the process of exercising oversight of the implementation of laws, prosecutors may request inspections by various Government bodies and the allocation of specialists to conduct departmental or interdepartmental inspections. In the context of the SLI, this means that labour inspectors may be involved in unplanned inspections initiated by law enforcement or oversight bodies if there are grounds for violations of labour rights or occupational safety rules. The SLI itself conducts both scheduled and unscheduled inspections to enforce labour legislation and occupational safety standards. These inspections not only assess legal compliance, but also verify whether employers have rectified violations previously identified by inspectors. Currently, there are no time restrictions on the duration of inspections carried out by labour inspectors. In 2018, the Government introduced a two-year moratorium (until 2020) on inspections of the financial and economic activities of business entities, aimed at accelerating economic development and promoting entrepreneurship. It is noteworthy that this moratorium did not apply to inspections conducted by the SLI.

Paragraph 4 of Presidential Decree No. PP-3913 of 20 August 2018 on measures to improve the structure of labour bodies and strengthen the system of protection of labour rights and occupational safety provides that the SLI shall conduct consultations with authorized bodies based on applications from individuals, legal entities or the tax service. The right to carry out unplanned short-term (up to one day) inspections of compliance with labour and occupational safety legislation without prior approval remains with the SLI. Moreover, under the Presidential Decree on measures to improve and enhance the effectiveness of State policy in the sphere of employment and poverty reduction, the requirement to obtain permission from the business ombudsman for conducting inspections was abolished in October 2024. Currently, electronic notification is sufficient.

In addition to inspections conducted with prior notification, Presidential Decree No. PP3913 mandates scheduled and unscheduled inspections in all organizations, regardless of ownership type. For example, during the cotton harvest in 2024, inspections were conducted without prior coordination with the competent authorities. Over 300 inspectors were involved in monitoring around 25,505 organizations, farms and cotton fields across the country to prevent forced labour and ensure decent working conditions. These inspections uncovered 520 violations, including 238 (46 per cent) related to poor working conditions, 102 (20 per cent) due to the absence of labour contracts and 180 (34 per cent) due to delayed wage payments. As a result, written instructions were issued to the heads of 330 farms, and administrative penalties were imposed on 23 officials under article 49(1) of the Administrative Offences Code (violations of labour and occupational safety legislation by officials).

The SLI operates in accordance with the Law on Appeals of Individuals and Legal Entities (new version dated 11 September 2017, No. ZRU-445). Article 19 prohibits the disclosure of private information or data that violates the rights or interests of citizens and legal entities, unless consent is given. Upon request, a complainant’s identity must not be disclosed. In 2024, the SLI received 27,166 appeals, of which 16,181 were upheld and 8,948 were clarified; 12,472 citizens had their labour rights restored. Additionally, 390 appeals were submitted to the business ombudsman and led to inspections of business entities – all of which were upheld.

Throughout 2024, the SLI conducted 18,807 control activities related to labour and occupational safety legislation, identifying 49,488 violations. As a result, 10,556 written orders and 435 mandatory representations were issued, and penalties were imposed on 8,281 officials. Of the 49,488 violations, 31,839 concerned labour rights violations, including: 5,844 – failure to provide leave; 4,542 – non-payment of wages; 2,022 – absence of employment contracts; 672 – informal employment; 2,172 – violations of employment legislation; 776 – unlawful dismissals; and 1,478 – violations of labour record procedures. A further 17,649 violations pertained to occupational safety and unsatisfactory working conditions, including: 3,047 cases of employees working without safety instruction; 2,198 cases of lack of safety training and certification; 1,194 cases of absence of protective clothing and equipment; 1,466 cases of lack of occupational safety plans; 844 enterprises with no medical examinations; 991 without established occupational safety services; and 551 without workplace condition certification. In 2024, 717 unlawfully dismissed workers (including 341 women) were reinstated, and assistance worth 75 billion Uzbek sum was provided to 9,970 individuals. There were 868 occupational accidents in 2024 involving 974 people: 261 fatalities, 683 serious injuries, and 30 minor injuries. Over 3.7 billion sum was paid in compensation to affected workers or their families.

The SLI may involve technical experts, including medical, electrical, chemical and engineering specialists, in inspections. While such experts have not yet been engaged, an expert working group exists within the SLI. The SLI maintains records as stipulated in Article 21 of Convention No. 81, and Article 19(1) and Article 27 of Convention No. 129, based on data submitted by employers through the interdepartmental Unified Labour System database (also available at dmi.mehnat.uz). According to Cabinet of Ministers Resolution No. 286 of 6 June 1997, all workplace accidents must be reported within three working days, analysed by the employer, and discussed with the workforce to prevent recurrences.

Article 26 of the Law on Occupational Safety requires the investigation and registration of occupational diseases, with procedures established for cooperation between employers, medical institutions and the SLI. Employers must notify the SLI of all occupational illnesses and corrective measures taken.

To improve transparency and efficiency, the Ministry is digitalizing SLI operations. The Unified Labour System will soon enable simplified procedures for handling violations, allowing inspectors to issue penalties electronically. A risk analysis system has also been introduced, using 13 criteria to assess risk levels without human involvement. Organizations with high or medium risk are audited automatically, and integration of this system with the Unified State Control System is under way.

Presidential Decree No. PP-347 of 4 April 2024 increased SLI staff by 16 per cent, from 345 to 412, including an increase in central staff from 17 to 22. All SLI staff were fully certified between February and March 2025, with several employees sent for retraining. Under Cabinet Resolution No. 246 of 27 April 2017, technical inspectors must undergo at least 36 hours of occupational safety training annually.

Article 249 of the Labour Code states that wage systems for public employees are determined by law. Article 252 provides that the rules for incentive payments are also set by legislation. The Ministry relies on these regulations when determining salary scales. Currently, the average inspector’s salary is 8–10 million sum. Positions in the State Tax Committee and Ministry of Internal Affairs are classified two grades below that of labour inspectors, making labour inspector salaries more competitive. According to Cabinet Resolution No. 424 of 2 August 2022, employees are reimbursed for travel, accommodation and per diem expenses while on official trips. As per paragraph 39 of the SLI Regulations (Appendix 3 to Cabinet Resolution No. 1066 of 31 December 2018), inspectors receive monthly bonuses of up to 10 per cent of fines collected, not exceeding 35.15 times the minimum wage. This system incentivizes impartial inspections.

Regarding trade union inspections, article 540 of the Labour Code grants trade unions the right to conduct public monitoring of labour legislation and collective agreements. They may examine workplace safety at various stages of a project, participate in investigations into accidents, attend expert medical commissions, and engage in dispute resolution and legal actions on behalf of workers. Unions may establish their own inspection services. Information collected by these inspectors is compiled and published on official union websites. As of 2025, 116 union inspectors are employed across the Federation of Trade Unions and its branches (9 women, 107 men). Their qualifications include those of lawyers, engineers, doctors, economists and other professionals. There are fundamental differences between the SLI and trade union inspectors: the SLI has legal authority to inspect all entities, impose penalties and produce official reports, while trade union inspectors operate within a limited membership scope and have no legal enforcement powers. Nonetheless, both systems complement one another within the framework of tripartism and social dialogue.

Currently, the ILO project entitled Improvement of Labour Inspection and Occupational Safety Systems in Uzbekistan (October 2024–December 2025) is being implemented. The Government would appreciate further ILO support in implementing Conventions Nos 81 and 129, and in enhancing the capacity of Ministry staff in reporting and Labour Inspectorate operations.

Discussion by the Committee

Chairperson – I have the honour to give the floor to the distinguished representative of the Government of Uzbekistan, the Minister of Employment and Poverty Reduction, for his opening statement.

Interpretation from Russian: Government representative – To begin with, I would like to thank the Committee for giving us the opportunity to share with you some information on the work that we have been doing in Uzbekistan, in order to implement Conventions Nos 81 and 129. Obviously, both Conventions are of key importance for guaranteeing workers’ rights, including such issues, as freedom of association and collective bargaining, as well as reducing the scale of informal employment and expanding opportunities for decent work.

Uzbekistan has ratified all fundamental and ILO governance Conventions and has demonstrated itself to be a partner capable of fulfilling its commitments in terms of their implementation.

We can go back a few years and recall that previous questions to Uzbekistan about systematic forced and child labour have been left behind. Uzbekistan is actually an example for demonstrating firm political will and for carrying out comprehensive reforms that have led to the complete eradication of these phenomena.

I would like the achievements that we have made to remain in the memories of the members of the Committee and to serve as a basis for trust, now and in the future, in our Government, that the other obligations that we have to comply with in relation to international labour standards will be fulfilled.

Uzbekistan has achieved considerable progress in laying down a legal and practical basis for implementing labour rights.

In 2019, we ratified Conventions Nos 81 and 129, but even before ratification, we carried out the first reform of our labour inspection system in 2018. We set up one single State Labour Inspectorate in April 2023. We brought into force a new Labour Code, which was developed with the support of ILO, World Bank and other partners. The Labour Code outlaws child and forced labour, enshrines the basis for collective bargaining, and aims at improving employment.

What is equally important is that the Government has taken decisions in respect of digitalization, which will enhance both the effectiveness and the transparency of the Labour Inspectorate.

I would like to go into further details on the changes which have taken place in Uzbekistan since the first report on these Conventions was submitted, so that the distinguished members of the Committee and the other Members of the ILO at this meeting can learn about the reforms and the challenges to which our Government is still trying to react.

First of all, the Committee of Experts appealed to us to withdraw the moratorium on the work of the Labour Inspectorate, noting that labour inspection should be able to be independent. It was put in place by a Government decision in 2018, in order to speed up economic development and promote entrepreneurship. It applied to the financial and economic activities of companies and enterprises, and later a procedure for obtaining permission from the business ombudsman to conduct inspections was introduced for labour inspections.

The Labour Code, which came into force in April 2023, establishes a free system for monitoring and supervising compliance with labour legislation and occupational safety rules. It has a greater legal force than the decision of the Government and, therefore, has removed the moratorium.

As part of institutional reform, in September 2024, the Presidential Decree on measures to improve and enhance the effectiveness of State policy in the sphere of employment and poverty reduction was adopted, formally abolishing the procedure for obtaining permission from the business ombudsman.

Now the Labour Inspectorate can carry out announced and unannounced inspections and there are no limits on the length of the inspection. The Labour Inspectorate can also hold consultations and inspect employers on the basis of information from legal and physical persons, the Prosecutor’s Office, the tax service and others.

The first stage of the digitalization of the Labour Inspectorate has been completed: a unified database has been created, which works in conjunction with the Unified Labour System and the Digital Tax Platform. Inspectors now have access to information about all registered companies and organizations and about all taxpayers, including those involved in what we describe as non-traditional forms of employment, that is, freelance workers, short-term workers, and people working on digital platforms, etc. The inspectors also have access to all labour contracts in this newly digitalized system.

There is also a rating of employers based on risk assessments of the possibility that they may commit any kind of infringement of the labour law.

At the moment, the practice of informing the business ombudsman for scheduled inspections is still in place. However, unscheduled inspections are carried out without prior notification.

Now there are two things I would like to mention. During the cotton harvest, which is the most sensitive sector in respect of labour issues in Uzbekistan, inspections are carried out without announcement, and with the involvement of inspectors from other organizations, such as medical professionals or health service officials.

Every year the ILO continues to cooperate with us in training inspectors, nongovernmental organizations and civil activists and guaranteeing independent monitoring of the situation in that area.

The practice of registering other inspections in the Unified Inspection Database and notifying the business ombudsman has been introduced to combat corruption. That is the first point I wanted to make.

Now, the second point brings me to where the Committee of Experts requested statistics about the quantity of inspections carried out with the authorization of the business ombudsman and those carried out as a result of complaints, as well as the quantity of requests for inspections and the number of cases where authorization was refused. From statistics, we can see that the number of inspections started by the inspection service itself has been going up every year. In 2023, the number was 920. By 2024, we were talking about a doubling of that figure and we had approximately 2,000 inspections. In five months of this year, the quantity of inspections started by the Labour Inspectorate itself exceeded 3,000. So, what we see is a positive trend. There is an increase in such inspections. The business ombudsman now has no way of influencing whether an inspection is carried out or not as a result of the changes made in October 2024.

The Committee of Experts also asked about the nature and number of violations identified during inspections, judicial proceedings and subsequent sanctions imposed, including their amounts. I will take the first five months of this year as an example. From January to May, 7,840 inspections were carried out and 15,512 infringements were detected. 3,655 warnings were issued, and if I am not mistaken, administrative fines were levied on 4,368 individuals.

The fourth question which was asked was the number of inspectors in the State Labour Inspectorate. After carrying out our institutional reforms, the number of inspectors increased from 380 to 412. Of course, we understand that this figure is not yet sufficient to fully cover and monitor compliance with labour legislation. Therefore, we are in the process of undertaking new reforms which will be brought into operation in the near future, and we hope that before the end of this year, the number of inspectors will have increased by a minimum of 100.

The fifth point raised by the Committee of Experts was the issue of labour inspections carried out by trade unions. Trade unions do have the right to what we call “social control”, which means that they can contact employers and submit representations to them regarding the elimination of violations of labour legislation or occupational safety rules, apply to the State Labour Inspectorate, and also to the courts in defence of the labour rights of workers. There are key differences however, between the functions of the State Labour Inspectorate and the inspectorate run by trade unions. The State Labour Inspectorate has, of course, the authority of the State behind it and can carry out checks and inspections in any enterprise or office. It can also apply administrative sanctions and hold employers responsible for infringements to legal responsibility. The inspection service run by unions carries out social control, does not have the same level of authority, and cannot apply sanctions. However, both systems complement each other and are part of our system of tripartism and social dialogue.

In conclusion, we do realize that we still have challenges that have to be met and problems that have to be overcome. We do know the situation in Uzbekistan is not perfect in respect of our compliance with our own labour legislation or international labour Conventions. However, this meeting has, in the past, been a platform for tripartite dialogue and a healthy exchange of opinions and, indeed, it offers an excellent opportunity for multilateral cooperation. It also helps all of us to meet the challenges we face. Therefore, believing in the spirit of cooperation, in order to achieve full implementation of the obligations under Conventions Nos 81 and 129, we request technical assistance from the ILO in addressing the remaining issues. First of all, it concerns assistance, and I will try to do this briefly, for improving our labour inspectorate system, strengthening labour inspection capacity, expanding trilateral dialogue, integrating labour policy into sustainable development, a communication strategy for labour inspection, and following ILO recommendations.

Worker members – It cannot be repeated too often: inspection services are essential to ensuring the effectiveness of rights and compliance with rules in the world of work. They are a vital public service, playing a central role in promoting decent working conditions and fundamental principles and rights at work.

To fulfil this mission, inspection services must be provided with an adequate legal framework and human, material and financial resources commensurate with the importance of their mission. Unfortunately, we are bound to observe that they do not benefit from all these guarantees in Uzbekistan.

As in other countries in the region, it is common to see a moratorium imposed on inspections. We have already seen this with Kyrgyzstan, and it is also the case in Uzbekistan. Such a moratorium was recently imposed on the financial and economic activities of establishments, with the exception of inspections carried out in the context of criminal cases or in connection with the liquidation of a legal entity. We understand that this moratorium has ended in the meantime, in December 2024. Under the moratorium, the only possibilities for the inspection services to intervene seemed to be in cases where a complaint was lodged with them. We can only support the conclusion of the Committee of Experts, which points out that a moratorium imposed on labour inspection constitutes a serious violation of the Conventions.

In addition, labour inspectors are subject to numerous restrictions in the course of their activities. A Presidential Decree of 15 March 2019 sets out the following restrictions:

• All inspections must be registered electronically.
• Any inspection carried out without such registration is illegal.
• The Commissioner for the protection of the rights and legitimate interests of business entities coordinates inspections and ensures that they are carried out in accordance with the law.
• The electronic inspection registration system allows the Commissioner to examine the validity of the authorities’ decisions to carry out inspections and issue a permit with a unique code for their implementation; and to verify that the authorities comply with the inspection procedure defined by law. It also allows business entities to receive, upon request, information about the inspection in the form of short messages (SMS), as well as via the internet in real time.

The same Presidential Decree also limits the duration of inspections. Another Presidential Decision of 2018 limits inspections in response to a complaint to one day, and also limits the scope of these inspections.

A Presidential Decree of 13 September 2022 contains further restrictions on the powers of inspectors. It sets out an endless list of restrictions:

• Inspectors are required to notify a business entity that an inspection will take place at least 10 working days in advance.
• Inspectors are not allowed to carry out re-inspections.
• Business entities have the right to refuse inspections if the order to carry out the inspection has not been issued in accordance with the established procedure or if the notification period for the inspection has not been respected.
• Inspections may only be carried out after preventive measures have been put in place.
• Inspectors must submit a request for approval to the Commissioner.
• The Commissioner also has the right to refuse inspections.

This Presidential Decree also stipulates that:

• The inspection order must contain the subject of the inspection, its duration, and the period of activity subject to inspection.
• During the inspection, officials of the supervisory authority must not exceed the specified time limit, the scope of their powers, and the issues defined in the inspection programme.
• Before starting an inspection, the inspector must inform the head of the business entity of the purpose of the inspection, present an official identity document authorizing the inspector to conduct the inspection, and provide copies of the documents that are the basis for the inspection.
• Lastly, inspections may only be carried out during working hours.

As you will agree, this Presidential Decree alone contains an impressive series of restrictions that are contrary to the Convention and do not facilitate the work of labour inspectors.

As if the list of restrictions was not long enough already, there are others restrictions to add. Workplaces that obtain certification through occupational safety and health audits cannot be subject to any planned inspection for three years.

The State Labour Inspectorate regulations, which define the powers of inspectors, omit important prerogatives that should be part of these powers. They are not empowered to question witnesses, employers or workers, or to take or remove, for analysis, samples of materials and substances used or handled.

In accordance with the Occupational Safety Act and the State Labour Inspectorate Regulations, when violations of the law are detected, labour inspectors are first required to issue an order to address the violations and take preventive measures. Only in the event of non-compliance with the order may inspectors consider administrative penalties on the basis of the Administrative Liability Code. However, inspectors themselves are not empowered to impose administrative fines. It is a court that must decide on the basis of the evidence provided by the inspectors.

These elements are not in conformity with the provisions of the Conventions, which provide that the decision to issue warnings or advice rather than initiate proceedings must be left to the discretion of labour inspectors.

Finally, the Committee of Experts’ report notes that the Labour Code provides that obstruction of labour inspectors in the performance of their duties may entail liability for the perpetrators, but does not provide for any penalties for such violations.

After listing these breaches of the Conventions under examination, you will understand that we share the deep concern expressed by the Committee of Experts in its report. All these factors are likely to seriously hamper the work of the inspection services in Uzbekistan.

We hope that the Government will engage in constructive dialogue with our Committee and all the ILO bodies concerned in order to follow up on the recommendations made to it and thus remove the many restrictions that place an unfair burden on the inspection services.

Employer members – The Employer members thank the Government of the Republic of Uzbekistan for their oral and written information on this case. The Employer members emphasize the importance of the Government’s compliance with Conventions Nos 81 and 129. These are governance or priority Conventions, as such they require special attention because of their importance for the functioning of the international labour standards system.

We would like to start by providing some background information and context. The Republic of Uzbekistan joined the ILO in 1992. It has ratified a total of 25 Conventions and one Protocol. This includes all ten fundamental Conventions, all four governance Conventions and 11 technical Conventions. The Republic of Uzbekistan ratified Conventions Nos 81 and 129 on 19 November 2019.

The Committee of Experts previously adopted an observation on the Government of the Republic of Uzbekistan’s application of Conventions Nos 81 and 129 in 2024. The Committee of Experts also previously made two direct requests to the Government of the Republic of Uzbekistan on the application of Conventions Nos 81 and 129. This year is the first time that the Committee has examined the Government of the Republic of Uzbekistan’s application of Conventions Nos 81 and 129.

The Government of the Republic of Uzbekistan has been going through a process of significant reforms to transition to a market economy. In the past few years, the Government has been working with the ILO to improve labour inspections and occupational health and safety systems in the country. However, significant gaps still exist.

The Committee of Experts’ comments relate to three issues regarding the Government’s application of Conventions Nos 81 and 129.

First, the Committee of Experts noted with deep concern that there is a temporary moratorium on labour inspectors imposed by law.

Second, the Committee of Experts noted with deep concern the extent and gravity of several measures imposed by law, restricting the ability and authority of inspectors to conduct labour inspections.

Third, the Committee of Experts noted deficiencies in the enforcement and penalties provisions in relation to labour inspections.

With respect to the first issue, the Employer members note that Article 16 of Convention No. 81 and Article 21 of Convention No. 129 state that workplaces shall be inspected as often and as thoroughly as is necessary to ensure the effective application of the relevant legal provisions.

The Employer members note the Committee of Experts’ deep concern that there is a temporary moratorium on most inspections imposed by Presidential Decree.

The Government provided information, noted in the Committee of Experts’ report, that the State Labour Inspectorate has the right to initiate an inspection within the framework of the issues raised in the complaint, notwithstanding the moratorium.

The Government also provided additional information on 20 May 2025 to the Office, disputing the existence of a moratorium on labour inspection and stated that there was an issue regarding the interpretation of the Presidential Decree imposing that moratorium. The Employers underscore the importance of ensuring that workplaces are inspected to safeguard the effective enforcement of legal provisions. As noted by the Committee of Experts in its general observation adopted in 2019 on Convention No. 81, a modern, well-designed and riskbased approach to labour inspection planning is compatible with Conventions Nos 81 and 129.

With respect to the second issue, the Employer members note that Article 12 of Convention No. 81 outlines the various powers to be granted to labour inspectors. These include the power to enter workplaces without prior notice. It also includes the power to carry out an examination, test or inquiry, including interrogating the employer or their staff on any matters concerning the application of legal provisions. Article 16 of Convention 129 includes similar provisions.

The Employer members note the Committee of Experts’ deep concern that the law by Presidential Decree contains a number of restrictions to the power of labour inspectors. These include the following:

• a requirement that labour inspectors obtain prior approval of inspections by an authorized body which can also refuse to provide approval in certain circumstances.
• during the inspection, inspectors are barred from going beyond the timeline and the scope of their powers and issues defined by the order of the authorized body.
• labour inspectors can only conduct inspections after preventive measures have been implemented.
• labour inspectors must provide prior notification to a business entity of the commencement of a labour inspection.
• business entities have the right to refuse inspections in certain circumstances.

Finally, the Employer members note the Committee of Experts’ observation that the regulations on the State Labour Inspectorate does not include the power to question alone or in the presence of witnesses the employer or its staff on matters concerning the application of legal provisions. They also do not have the power to take or remove for purposes of analysis samples of materials and substances.

In order to ensure the effectiveness of the governance of labour standards and the application of labour standards in law and in practice, the Employer members emphasize the importance of providing labour inspectors who hold the proper credentials with the powers outlined in Conventions Nos 81 and 129.

With respect to the third issue, the Employer members note that Article 17 (2) of Convention No. 81 states that it should be left to the discretion of labour inspectors to give warning and advice instead of instituting or recommending proceedings. Article 22 (2) of Convention No. 129 contains a similar provision.

Moreover, Article 18 of Convention No. 81 states that national laws or regulations must provide for adequate penalties for violations of the legal provisions and for obstructing labour inspectors in the performance of their duties. Article 24 of Convention No. 129 contains a similar provision.

The Employer members note the Committee of Experts’ observation that, under the applicable Occupational Safety Act and the regulations on the State Labour Inspectorate, when violations of the law are detected, labour inspectors will first issue an order to take preventive measures. The Employer members also note the Committee of Experts’ observation that the Labour Code establishes liability for the obstruction of labour inspectors. However, it does not specify any sanctions for such a violation.

The Employer members urge the Government of the Republic of Uzbekistan to comply with the effective enforcement and adequate penalties provisions of Conventions Nos 81 and 129. In order to ensure the effectiveness of the governance of labour standards and the application of labour standards in law and in practice, there must be an effective enforcement mechanism which includes adequate penalties. Issuing orders to take preventive measures must also be coupled with instituting or recommending proceedings. Furthermore, there should be sanctions for parties who obstruct the work of labour inspectors.

In conclusion, the Employer members strongly urge the Government of the Republic of Uzbekistan to commit to meeting the requirements of Conventions Nos 81 and 129 both in law and in practice.

Interpretation from Russian: Worker member, Uzbekistan – It is an enormous honour to speak today on behalf of the Federation of Trade Unions of Uzbekistan (FPU). Bearing in mind that Uzbekistan has ratified Conventions Nos 81 and 129 concerning the work of the Labour Inspectorate, normative and legal acts and laws in our country should be brought into accordance with the requirements of those Conventions. They are also supposed to be applied in practice. That is a priority for our Federation and it is something that we have brought up at tripartite consultation meetings more than once.

We are grateful to the Committee of Experts for having gone into detail into the situation with respect to the application of the Conventions in practice. We note that, with ILO support and the participation of tripartite partners, we have already carried out a comprehensive overhaul of the activity of the State Labour Inspectorate.

In autumn 2024, the Government decree lifted the moratorium on inspections. This is a positive step forward. We hope that further steps will follow, so that the work in Uzbekistan will lead to compliance with these Conventions in practice.

On its side, the FPU, in order to exercise public control over compliance with regulatory and legal documents relating to the socio-economic rights and interests of workers, as well as regulatory documents in the field of technical regulation, on the basis of the Law on trade unions, set up in 2020 a Labour Inspectorate within the FPU.

We had 50 inspectors at first. We now have over 100 inspectors working across the union at local, branch and regional levels. The inspectors not only find infringements and advise on how to tackle them, they also carry out awareness-raising activities among workers, informing them about their labour rights and occupational safety.

During the period in which they have been working, they have carried out 3,520 educational and awareness-raising events. They have also held seminars and webinars with unionized workers, so as to enhance their knowledge and skills. We hope this work will lead to preventing infringements, saving lives and protecting the health of workers and also change the culture of labour relations in the workplace.

On the basis of a monitoring plan for workers’ rights and the establishment of decent work, which was developed by the Ministry of Employment and Poverty Reduction, the FPU and the Confederation of Employers in our country conduct monthly checks and investigations in various branches of the economy.

The workers of the Labour Inspectorate have participated actively in the national monitoring of conditions in the cotton harvest, in particular to prevent child and forced labour during the harvesting season. The FPU also organized a system of feedback so that it could work constantly on this issue.

Of course, we still recognize that we have challenges to meet, particularly in fully implementing the provisions of Conventions Nos 81 and 129 on the effectiveness and independence of the Labour Inspectorate, including in agriculture.

The unions of Uzbekistan believe that an effective and independent system of labour inspection is of decisive importance for ensuring compliance with labour rights and improving working conditions. We think there are key challenges we have to address, which arise in our national labour market and which have a direct influence on the possibility of the Labour Inspectorate to carry out its work properly.

Firstly, in our country we still have a very high level of informal employment, especially in agriculture, construction, small business and the services sector. It is thought that the vast majority of workers are not covered by active labour contracts. They are not registered in the official system and, as a result, they are deprived of their basic social and legal protection. This limits significantly the ability of the Labour Inspectorate to carry out monitoring and requires a review of the methods used to cover the informal sector.

Secondly, labour migration remains a major issue for us, especially with Uzbek citizens leaving to work abroad. Quite often, the rights of these migrants to decent working conditions and labour protection, as well as safety in the workplace, are not guaranteed.

We appeal for more international cooperation in the area of labour inspection, including through bilateral agreements, exchange of information and coordination between the labour inspectorates of different countries.

Thirdly, the Labour Inspectorate in Uzbekistan comes up against problems of an institutional nature. That means a lack of inspectors, insufficient provision of equipment and a lack of training for officials. Quite often, the inspectors do not have sufficient access to industrial sites, or they suffer pressure exerted by employers, particularly in the private sector. This undermines trust felt by the workers in the fact that their rights will be protected.

Furthermore, as we digitalize the economy and as non-standard forms of employment spread, such as working freelance, temporary contracts and platform work, there is a need to adapt the mechanisms of our Inspectorate.

Law and inspection practices should take into account the new realities in the world of work and protect the rights of all workers, whatever the form of employment they are engaged in.

In conclusion, let me underscore that strengthening the Labour Inspectorate is impossible without the full development of social dialogue. Unions should be actively involved in the process of monitoring conditions at work, provide information on violations and also be involved in developing decisions and strategies at all levels. We insist on the need for regular participation of unions in the action of the Inspectorate, including in carrying out joint inspections and risk assessments.

We believe that the effectiveness of the State Labour Inspectorate should be determined by the number of violations prevented, the amount of lives saved, and the growth of understanding by workers and by employers of their rights, rather than by formal reporting on investigations of violations that have already occurred.

In this regard, we request further technical assistance from the ILO, including expert support, training for inspectors, development of methodological materials and assistance in the institutional development of inspection bodies.

We are convinced that, with the ILO’s support and through active social dialogue, we will be able to improve the monitoring of labour rights and ensure decent working conditions for all the workers of Uzbekistan.

Interpretation from Russian: Employer member, Uzbekistan – I would like to make one or two comments on the topic under discussion today. The Employers of Uzbekistan consider that we need to first of all, increase the transparency, independence and status of the State Labour Inspectorate in Uzbekistan. As we see it, a strong inspection service is a guarantee of fair, honest and high-quality control.

As employers, we note that the inspection service participates actively in tripartite dialogue and in bilateral cooperation with our Employers’ confederation.

As an example, let me say that the inspectorate always actively cooperates with our organization and it has been an active participant in events that we have held.

At the beginning of this year, for example, it started to participate in meetings with us and, so far, it has participated in six meetings which have looked at the work of the Labour Inspectorate and at the problems with its work that we have identified.

At the same time, the current rules governing the State Labour Inspectorate in its work are not fully in accordance with Convention No. 81, which, as we know, was ratified by the Republic of Uzbekistan in 2019.

We would like to draw your attention, with your permission, to several challenges that we see:

• First of all, it is an institutional challenge, by the simple fact that we do not have sufficient numbers of labour inspectors in our country.
• Secondly, and because of that, each inspector has far too much work to do. The result of that is that they do quick and superficial inspections and that leaves us a bit doubtful about the outcome and the conclusions.
• Thirdly, there is a system of bonuses for labour inspectors in Uzbekistan, which is based on a percentage of the amount levied as fines. This is still operating and we fear that this does not really enhance trust among employers, the kind of trust we would like to have in the conclusions reached and the measures taken.
• We think that the Labour Inspectorate should be the only body responsible for carrying out inspections in our country, but as my colleague, I think, indicated, there is what is described as a trade union inspectorate that carries out what is known as social control. It is true that this service does not have the possibility of giving fines or other punitive measures, but according to Convention No. 81, labour inspection at companies and in industries and agriculture is supposed to be carried out only by a State body. This worries us as employers, and we think it undermines both the independence and the transparent status of the State Labour Inspectorate.
• Furthermore, there are not sufficient numbers of inspectors in Uzbekistan who are trained in carrying out inspections at more specialized enterprises.

If inspectors do not have the necessary qualifications, they cannot do a proper job. Each sector of the economy has its own characteristics, its own features and inspectors have to know the method to carry out inspections correctly.

What measures do we think are necessary to deal with this situation?

Well, firstly, there has to be an increase in the numbers of labour inspectors in Uzbekistan. That is extremely important.

We also agree that something needs to be done, and here I agree with my colleague about the system of bonuses for inspectors, because that really is a problem for us. We would like that to be changed. We heard our colleagues mention this, too, that the imposition of fines and the handing down of punitive measures is an issue.

I mentioned the system of inspections in the FPU. We would prefer to suggest a change of name for that. We could call it something like the “social monitoring service”, but not the “Labour Inspectorate”, so that we do not have this issue of confusion between that body and the work of the State Labour Inspectorate. It simply causes confusion and also leads to a reduction in the authority of the State Labour Inspectorate. We would like the Labour Inspectorate to be working in partnership with the employers of Uzbekistan and not to be seen as a body whose purpose is punitive.

We do understand also that there is a need to do preventive work, which means better cooperation between business and the Labour Inspectorate to ensure that the law is observed and to minimize infringements, infractions and violations in the first place.

Lastly, the employers of Uzbekistan and, indeed, our Uzbek colleagues from the Union, believe it is absolutely correct that the employers of Uzbekistan would like to be observers when State inspections are carried out, so that we can guarantee that what is being done is both correct and transparent. I mentioned transparency at the beginning, and it is very important to us in every sense. It is equally important to us that our rights and duties as employers in Uzbekistan are governed by the law and that the law in respect of the Labour Inspectorate is properly observed.

Let me say in conclusion that, of course, we are unable to achieve any of this without the technical support and advice of the ILO. As employers in Uzbekistan, I would like to echo the call for support to Uzbekistan in general and to the employers’ organization in Uzbekistan, so that we can all work together to improve our mechanisms through tripartite dialogue and thereby, enhance the quality of the Uzbek Labour Inspectorate and its work. We do think that a strong Labour Inspectorate, as I said, is a guarantee of many things, including economic growth, but only if it works equally and impartially with the employer’s organization, the unions and the Government. We want a balanced system which does not lurch in favour of, or against, one side or the other. If we obtain that, then we’ll be heading in the right direction.

Government member, Poland – I have the honour to speak on behalf of the European Union (EU) and its Member States. The candidate countries, Albania, Montenegro, North Macedonia, Republic of Moldova and Ukraine, and Norway, member of the European Economic Area align themselves with this statement.

The EU and its Member States are committed to the respect, protection and fulfilment of human rights, including labour rights.

We promote the universal ratification and effective implementation of fundamental ILO Conventions and support the ILO in developing and promoting international labour standards and supervising their application.

Labour inspection as provided for in Convention No. 81 is key in promoting and safeguarding decent working conditions.

In 2021, Uzbekistan became a beneficiary of a special incentive arrangement for sustainable development and good governance of the EU generalized scheme of preferences, the GSP plus, which, in addition to generous market access, offers a platform to exchange on and promote sustainable development based on Uzbekistan’s commitment to the effective implementation of 27 international Conventions, particularly on human rights, including labour rights and environmental protection and climate change and good governance. Moreover, the EU and Uzbekistan concluded negotiations in 2022 on an enhanced partnership and cooperation agreement which aims to extend their relationship into new areas of cooperation.

Lastly, the EU supports Uzbekistan’s reform agenda through technical and financial assistance, including concerning labour rights. The moratorium placed on labour inspection in force since September 2018 is a serious violation of Conventions Nos 81 and 129.

We note with deep concern that at present no scheduled inspections are conducted in business entities due to this moratorium on inspections of the financial and economic activities of business entities.

In line with the Committee of Experts’ recommendation, we urge the Government to eliminate the temporary ban on inspections and to ensure that labour inspectors are able to undertake labour inspections as often as necessary to ensure the effective application of the Conventions.

Furthermore, we note with deep concern the extensive restrictions on labour inspections. We appeal to the Government to take the necessary measures to ensure that labour inspectors are not limited in their work.

They must be empowered to make visits to workplaces liable to inspection without previous notice, to carry out any examination, test or inquiry which they may consider necessary, to choose not to notify the employer or his representative of their presence and to undertake labour inspections as often and as thoroughly as it is necessary.

We also recall the importance of ensuring that labour inspectors treat as absolutely confidential the source of any complaint and give no intimation to the employer that an inspection was made in consequence of such a complaint.

Lastly, labour inspectors should be empowered to ensure effective enforcement and adequate penalties such as administrative fines. We reiterate the Committee of Experts’ call to introduce sanctions for cases of obstruction of labour inspectors in the performance of their duties. In this context, we welcome the implementation of the Decent Work Country Programme 2021–25. We also welcome the implementation of the ILO project on the improvement of labour inspection and occupational safety systems in Uzbekistan in 2024–25.

We thank the Office for its active engagement in the promotion of labour rights and welcome the fact that Uzbekistan avails itself of ILO technical assistance.

We took note of the written information provided by the Government of Uzbekistan, including the rationale that the moratorium introduced on inspections of the financial and economic activities of business entities was aimed at accelerating economic development and promoting entrepreneurship.

We encourage the Government to provide further information related to the practical application of Conventions Nos 81 and 129, in order to respond to the Committee of Experts’ requests.

The EU and its Member States stand ready to support Uzbekistan with the aim of strengthening the Government’s capacity to address the issues raised and in meeting its obligations under the ratified Conventions. We will continue to follow closely the situation in the country.

Government member, Cuba – Cuba acknowledges the positive progress made by Uzbekistan in implementing the ILO Conventions on labour inspection, specifically Conventions Nos 81 and 129. Since the ratification of the Conventions in 2019, Uzbekistan has worked actively to strengthen its State Labour Inspectorate, ensuring compliance with labour and occupational safety legislation in all sectors, including agriculture.

The country has implemented a more efficient and transparent inspection system, with planned and unplanned inspections that verify compliance with labour standards and the rectification of previously identified violations. In the agricultural sector, the labour inspection entity has intensified its supervision to prevent forced labour and improve working conditions, especially during the cotton harvest. In addition, it has introduced digital tools to optimize labour inspection. The risk analysis system, based on automated criteria, makes it possible to identify the most vulnerable sectors and prioritize audits in high-risk organizations. In terms of results, in 2024, the Labour Inspectorate carried out approximately 19,000 control activities, detecting thousands of violations of labour regulations. As a result, more than 10,000 written orders were issued and sanctions were imposed on 8,281 officials.

Cuba recognizes the efforts made by Uzbekistan in implementing Conventions Nos 81 and 129 and its commitment to labour inspection as a fundamental pillar for ensuring decent work and social justice. We trust that this process will continue to move forward, with the support of the ILO and international cooperation.

Worker member, Germany – I speak on behalf of the German trade unions and wish to express our concern about the violations of Conventions Nos 81 and 129 by the Government of the Republic of Uzbekistan. In line with the Committee of Experts’ findings on Conventions Nos 81 and 129, we note that current labour inspection practices in Uzbekistan do not meet the required standards of scope, frequency or impartiality. We are deeply concerned about the 2018 moratorium placed on labour inspections, which represents a serious breach of the said Conventions. Unscheduled inspections are critical to prevent workplaces from concealing hazards before inspectors arrive. The ten-day advance notice requirement for inspections is a fundamental violation of the Conventions posing serious risks to workers’ health and safety.

Inspections focus on investigating and sanctioning infringements of labour standards and enterprises. Currently, a significant majority of inspections are conducted in response to complaints. Regular routine inspections must be intensified. Preventive inspections are crucial to prevent workplace accidents and tragedies before they happen.

To date, labour inspectors lack the authority to impose sanctions, to the detriment of their effectiveness.

Further, we emphasize that independent labour unions are essential for effective labour inspection and occupational safety. Therefore, it is impossible to address Conventions Nos 81 and 129 in isolation. The lack of truly independent labour unions is fundamental to commenting on the present case.

The FPU remains the sole workers’ federation in the country and serious concerns persist regarding its independence.

The union is State funded, and its leadership frequently includes individuals who hold Government positions. For example, the current head of the FPU is a senator. The first deputy is head of the Prime Minister’s Secretariat. As a result, the distinction between Government and trade unions remains blurred. In 2019, the adoption of the law on trade unions aimed to strengthen and clarify union rights. However, six years later, the law has failed to address concerns about union independence. Workers attempting to form independent unions remain unprotected and efforts to establish an independent union, as attempted in the cotton sector in 2021, were thwarted by State repression.

We noted that a German organization was approached to support the formation of a trade union in the country’s important textile sector. The German organization witnessed that the endeavour was driven by commercial actors and therefore declined the request to support the said trade union formation. German workers’ representatives remain firmly committed to the principles enshrined in the Freedom of Association and Protection of the Right to Organise Convention, 1948 (No. 87), and call upon the Uzbek Government to take meaningful steps towards implementation. We welcome the Government’s intention to increase the number of inspectors.

However, to ensure truly independent and effective labour inspections, Uzbekistan must fundamentally improve with regards to freedom of association, as occupational safety is indispensably linked to independent unions. Keeping the general situation of trade unions in mind, we call for immediate action by the Uzbek Government to immediately lift the 2018 moratorium on labour inspections, and to abolish the mandatory pre-registration of labour inspections. We call for a shift in the approach to labour inspections, placing greater emphasis on prevention. Also, we call for the authority to issue sanctions for labour inspectors and, lastly and most importantly, we call for the full implementation of Convention No. 87 in Uzbekistan.

Government member, Pakistan – Pakistan acknowledges the constructive efforts of the Republic of Uzbekistan to enhance its labour inspection system, in line with Conventions Nos 81 and 129. We have noted the substantial progress made in strengthening legal frameworks, improving institutional capacities and promoting compliance in both general and agricultural sectors. Uzbekistan’s continued engagement with the ILO supervisory mechanisms reflects its commitment to international labour standards. Pakistan supports a fair, balanced and forward-looking assessment of this case and encourages ongoing dialogue and cooperation to further consolidate these achievements.

Interpretation from Arabic: Government member, Oman – Oman would like to commend Uzbekistan for their efforts to bring themselves into compliance with international labour standards, particularly with regards to Conventions Nos 81 and 129. We also pay tribute to Uzbekistan’s cooperation with the Committee, in order to strengthen constructive dialogue with the ILO. As a result, we have seen that there has been technical assistance in order to enhance the implementation of these Conventions, thereby improving the drawing up of reports and statistics and ensuring the capacities of inspectors. We welcome these efforts and would like to reiterate how important our Committee is with regard to helping countries to comply with international labour standards, particularly with regard to allowing for sustainable development.

Government member, Switzerland – While commending the efforts by the Government, Switzerland remains concerned by the comments of the Committee of Experts regarding the situation concerning labour inspection in Uzbekistan. This situation is characterized by periods of suspension of labour inspections, as well as numerous restrictions on the exercise of the functions and powers of labour inspectors.

While noting the information provided by the Government, including the lifting of the moratorium on labour inspections, we encourage the Government to step up its efforts to ensure the proper functioning of the labour inspection system. We recall that it must be possible to carry out labour inspections without previous notice and as often and as thoroughly as necessary, and we therefore encourage the Government to lift the restrictions resulting from Presidential Decrees adopted several years ago which are still in force. These restrictions include:

• the requirement to give notice of inspections at least ten working days in advance;
• the requirement to obtain prior authorization, and the right of establishments to refuse an inspection if this procedure is not followed;
• the prohibition of carrying out repeat inspections;
• the impossibility for labour inspectors to question the employer or the staff, or to take or remove samples for purposes of analysis.

We note with interest the information indicating that efforts are under way to establish legal penalties for obstructing labour inspectors in the performance of their duties, and to ensure their effective enforcement in practice.

Finally, Switzerland encourages the Government to continue its cooperation with the ILO under the Decent Work Country Programme 2021–25, with a view to complying, in law and in practice, with its international obligations under Conventions Nos 81 and 129.

Interpretation from Chinese: Government member, China – We thank the President and the representative of the Government of Uzbekistan for the presentation. We have carefully reviewed the report of the Committee of Experts and the written materials submitted by the Government to the Committee. We note with appreciation that Uzbekistan attaches great importance to fulfilling its obligations under ILO Conventions, actively engages in cooperation with all parties, continues to advance reforms and promotes decent work and social justice.

The State Labour Inspectorate of Uzbekistan conducts regular and ad hoc inspections of employers in accordance with the law. The inspectors retain the authority to carry out unannounced inspections without prior approval and are unaffected by the Uzbek Government’s 2018 suspension of inspection measures. In response to comments from relevant parties, the Government of Uzbekistan provided detailed and targeted replies, including information on recent inspections and the handling of complaints. In 2024, Uzbekistan issued a Presidential Decree increasing the staffing of the State Labour Inspectorate by 16 per cent and at the beginning of this year, it conducted a comprehensive certification for all inspectorate personnel. The Government’s proactive and constructive approach deserves recognition by this Committee.

We welcome the ILO project on the improvement of labour inspection and occupational safety systems in Uzbekistan, which supports the analysis of existing national legislation at Uzbekistan’s request. We support the ILO in continuing to provide technical assistance to Uzbekistan to enhance the labour inspection capacity of relevant departments and to help the country to better fulfil its obligations under the Conventions.

Government member, Bolivarian Republic of Venezuela – The Bolivarian Republic of Venezuela thanks the Government for sharing a holistic view on the progress made and challenges faced in labour inspection and legislation in Uzbekistan. We appreciate the Government’s willingness to fulfil these responsibilities by promoting reforms that foster decent work, social justice and the protection of workers’ rights.

We note the recent measures implemented to strengthen labour inspection capacity, including the increase in personnel in the labour inspection services and continuous staff training. We also recognize that the digitalization of processes, the use of risk analysis, and the simplification of administrative procedures will be essential to improving the efficiency and transparency of inspection.

We emphasize the importance of social dialogue and cooperation with the various social actors, who, in addition to performing representative functions, actively participate in inspection activities, thereby complementing and strengthening the Government’s efforts in this regard.

To conclude, we urge the ILO to foster cooperation and technical assistance with the Government, with a view to further strengthening the country’s labour inspection and occupational safety systems. All of this in accordance with international Conventions, in support of a fairer, safer and more sustainable labour system.

Government member, Türkiye – Türkiye commends Uzbekistan’s ratification of all fundamental and governance Conventions and notes with appreciation the recent reforms, including the ratification of 11 ILO instruments within the last five years, which reflects a strong political commitment to labour rights and institutional development.

In light of Uzbekistan’s comprehensive reforms, Türkiye welcomes the Government’s clear political will to integrate Conventions Nos 81 and 129 into national practice. We note that the adoption of the new Labour Code in April 2023, coupled with the development of digital inspection systems and nationwide inspectors’ training supported by the ILO and Germany, reflects a holistic strategy, aimed at sustainable compliance and institutional capacity-building.

The full eradication of forced and child labour in agriculture, internationally recognized in 2022, demonstrates the tangible impact of these reforms. Uzbekistan’s model offers valuable lessons for rights-based governance and digital transformation in labour inspection systems across the region. We particularly welcome the recent removal of the requirement for business ombudsman approval for inspections, as well as the reintroduction of both planned and unannounced inspections in 2024, and the active enforcement efforts during the 2024 cotton harvest.

Türkiye notes with appreciation the progress made in institutional capacity-building, including the expansion of the State Labour Inspectorate staff, enhanced digital inspections such as the risk-based analysis system, and the increased transparency enabled by electronic sanctioning procedures.

We further highlight the strong record of performance in 2024, with nearly 50,000 violations identified, over 12,000 workers’ rights restored, and more than 8,000 officials held accountable.

At the same time, we encourage the Government of Uzbekistan to further align the powers of the State Labour Inspectorate with the full scope of Conventions Nos 81 and 129, including the ability to interrogate witnesses, collect samples, and act with independence and without undue procedural constraints.

We welcome the ongoing ILO technical cooperation project and support Uzbekistan’s request for continued assistance, particularly in the areas of legislative alignment, statistical capacity-building, and inspector training. Finally, we believe that Uzbekistan’s continuing reforms, coupled with open engagement with ILO’s supervisory system, will further advance the protection of workers and the realization of social justice.

Interpretation from Arabic: Government member, Saudi Arabia – Our delegation has taken note of the clarifications provided by Uzbekistan regarding developments in the national labour inspection system. We welcome the constructive cooperation with the ILO technical mechanisms and the comprehensive information provided, which demonstrate a clear commitment to dialogue and transparency. We welcome the progress made in strengthening institutional inspection capacities through regulatory reinforcement, capacity-building, etc. We also welcome Uzbekistan’s gradual approach based on progressive evaluation, a participatory approach and coordination with the social partners. We underline the importance of technical cooperation with the ILO. In conclusion, Saudi Arabia reiterates its full support for Uzbekistan’s efforts and encourages it to continue reforms to establish a balanced and effective inspection system to facilitate compliance and improve working conditions, taking into account national priorities and international commitments.

Observer, International Union of Food, Agricultural, Hotel, Restaurant, Catering, Tobacco and Allied Workers’ Associations (IUF) – Speaking on behalf of the IUF, we thank the Committee of Experts for the information provided and we thank the Government of the Republic of Uzbekistan for the detailed and honest report on the implementation of Convention No. 81.

Unfortunately, we cannot say that sufficient information is provided on Convention No. 129. Each Member of the ILO for which this Convention is in force, shall maintain a system of labour inspection in agriculture. The competent authority shall define the line which separates agriculture from industry and commerce, etc.

We regret to say that the figures given in the Government’s written and oral reports do not indicate in which sectors the inspections and the work of the Labour Inspectorate were carried out. It does not separate agriculture, and it is impossible to see from the report if and to what extent the agricultural sector specifically referred to in Convention No. 129 is covered by this work. We would like to recall that agriculture has one of the worst fatal accidents and occupational ill health records of any major employment sector.

Uzbekistan is one of the key suppliers of cotton to the international market and the issues of labour protection and respect for fundamental rights of workers in agriculture are of great importance here, especially for companies planning to invest in this industry after a long period of distrust and boycott of Uzbek cotton, which was caused by the systematic and massive use of forced labour of children in cotton farming. It was only three years ago, in March 2022, that the international boycott of Uzbek cotton was lifted. This was achieved through a remarkable effort of the Government to reform the industry and eliminate systematic child and forced labour.

Amid the general improvement, we still cannot ignore the regular reports from the country about problems with violations of human rights of agricultural workers and small farmers. This unfinished work keeps hindering the sustainability of the sector.

An example of this is a recent assessment by the European Bank for Reconstruction and Development of its funded project run by one of the agro-industrial companies in Uzbekistan, to which the Government allocated about 55,000 hectares for cotton cultivation in the Kashkadarya and Syrdarya regions. The cotton workers at these plantations made several attempts to unite, but all of them ended in the same way: the union was suppressed.

The Labour Inspectorate approached the situation concerning poor working conditions and safety standards in this area, but was not able to do anything, simply because workers were afraid to contact the labour inspectors and to openly and freely complain about the problems.

The situation perfectly illustrates the futility of efforts to strengthen inspections in the absence of freedom of expression, assembly and association.

The IUF submitted the complaint to the Committee of Freedom of Association, which is registered under No. 3487. We urge the Government of Uzbekistan to restore the right to freedom of association under Convention No. 87 and the Right to Organise and Collective Bargaining Convention, 1949 (No. 98).

Interpretation from Russian: Government representative – As speakers have pointed out, over the last two years the Uzbek Government has made quite a few changes to its legislation, including the adoption of the new Code I mentioned and the various other laws which have been put on the statute books. The moratorium that people have been talking about was withdrawn last year and so have certain other inappropriate procedures.

As I said, the system for carrying out inspections has now been improved. Having said that, the comments you have made, both positive and negative, and the suggestions you have put forward will all be taken into account by our authorities.

We understand your concern and we are quite happy to go back and check our legislation again and make changes and amendments where those are necessary, in order for us to be fully compliant with Conventions Nos 81 and 129.

We are coming to the final stages of the adoption of the separate document, which will improve the effectiveness and the solidity of our Labour Inspectorate and, as I said, in so far as possible, we will increase the number of inspectors, the quality of inspections and set appropriate levels for fines when they need to be levied. We also intend to improve the training and retraining provided to our inspectors.

We hope that, in taking into account the comments which have been made today and making the necessary amendments to our legislation and our procedures and practices, we will be able to improve the situation and bring ourselves fully into compliance with ILO standards.

Of course, we are open to constructive criticism and comments from the Committee of Experts and express our willingness to engage in dialogue with this Committee as and when necessary, and we hope that our needs will be taken into account and the assistance we need will be forthcoming in future technical cooperation with this Organization.

Employer members – The Employer members thank the various speakers who took the floor and, notably, the Government of the Republic of Uzbekistan for their intervention and information. The employers remind the Committee that Conventions Nos 81 and 129 are governance Conventions. The two Conventions ensure the effectiveness of the governance of the application of labour standards in practice.

As noted by the Employer members in our opening remarks, the Government of the Republic of Uzbekistan has been working with the ILO to improve labour inspections and occupational health and safety systems in the Republic of Uzbekistan. The Employer members acknowledge recent technical cooperation efforts between the Government and the ILO, including inspector training and study visits. However, these initiatives alone are insufficient to address the serious legislative and administrative barriers to effective labour inspections identified by the Committee of Experts.

The Employer members also acknowledge the request from the Government of the Republic of Uzbekistan first made on 8 May 2025 to the ILO Director-General for the ILO to provide technical assistance to ensure the full implementation of Conventions Nos 81 and 129.

On the basis of our earlier statements and, in light of the observations of the Committee of Experts, the Employer members recommend that the Government of the Republic of Uzbekistan do the following.

Number one, take the necessary measures to ensure that labour inspections are undertaken as often and as thoroughly as is necessary to ensure the effective application of legal provisions, including by ensuring that labour inspectors enter a workplace without prior notice. Labour inspectors carry out any examination, test or inquiry which they may consider necessary in order to satisfy themselves that the legal provisions are being strictly observed. This also includes interrogating alone or in the presence of witnesses the employer or their staff on any matters concerning the application of legal provisions, as well as labour inspectors notifying employers of their presence, unless they consider that such notification may be prejudicial to the performance of their duties.

Number two, for the Government to take necessary measures in order to ensure that effective and adequate enforcement and penalties are in place. This includes ensuring that labour inspectors have the power to exercise their discretion to give warning and advice, instead of instituting or recommending proceedings and establishing adequate penalties for obstructing labour inspectors in the performance of their duties.

Number three, provide the Committee of Experts with the various information requested.

Number four, be granted technical assistance as per the request from the Government of the Republic of Uzbekistan.

We trust that the Government of the Republic of Uzbekistan will provide their requested information by 1 September 2025 and adopt the measures indicated by this Committee in a timely manner.

Worker members – We thank the Government representative for the written and oral information he has provided. During our discussions, we noted that there are numerous violations of the Conventions in Uzbekistan. The recurring application of moratoriums on inspections is a source of deep concern. This is a serious violation of the Conventions. The Government should permanently lift all moratoriums on inspections in the country and ensure that such moratoriums are not reintroduced in the future.

We believe it is essential to strengthen the inspection services. We have noted the efforts of the Government to increase the number of labour inspectors and encourage it to intensify its efforts in this area. However, it will not be enough to simply increase the number of inspectors. It will also be necessary to ensure that they are trained and provided with all the necessary material and financial resources.

We have already reviewed the list of restrictions imposed on labour inspectors. Without revisiting this list, we nevertheless call on the Government to amend the relevant legislation in order to remove all the restrictions identified.

Hence the Government should take the necessary steps to ensure that labour inspectors:

• are authorized to carry out inspections without previous notice to any workplace liable to inspection;
• are authorized to carry out any examination, test or enquiry deemed necessary to satisfy themselves that the legal provisions are being observed;
• can choose not to notify the employer or their representative of their presence if they consider that such notification would prejudice the effectiveness of the inspection;
• can inspect establishments as often and as thoroughly as is necessary to ensure the effective application of the legal provisions.

A sufficient number of inspection visits without prior notice is necessary to enable inspectors to fulfil their obligation of confidentiality with regard to the source of any complaint, but also to avoid the establishment of any link between the inspection and a complaint. This is why we ask the Government to indicate the measures taken to ensure that inspectors treat the source of any complaint as strictly confidential and refrain from revealing to the employer or their representative that an inspection visit has been carried out further to a complaint.

The Government should also indicate the number of scheduled inspections carried out on the basis of the authorization of the Commissioner for the protection of the rights and legitimate interests of business entities, as well as the number of such inspections carried out further to a complaint.

The Government should also provide information on the number of requests for inspection submitted to the Commissioner and the number of cases in which such authorization was refused, indicating the reasons for the refusal. In its written information, the Government provides figures on the number of inspections carried out and the number of violations detected, but does not break down these figures as requested by the Committee of Experts.

The Government should also ensure that labour inspectors are free to decide whether to issue warnings or advice rather than institute or recommend proceedings. It should also provide information on the nature and number of violations detected during inspections, the number and nature of proceedings brought before the courts and the penalties subsequently imposed, including the amount of fines.

Finally, we request the Government to ensure that penalties are provided for in cases where labour inspectors are obstructed in the performance of their duties.

As the Government itself suggests, it will be important for it to continue to avail itself of ILO technical assistance to implement all the recommendations made. We ask the Government to do so by agreeing to an ILO direct contacts mission. We invite it to consider, in this context, the renewal of the “Improvement of Labour Inspection and Occupational Safety Systems in Uzbekistan” project, which was set up in collaboration with the ILO and will finish at the end of this year.

Conclusions of the Committee

The Committee took note of the oral and written information provided by the Government and the discussion that followed.

The Committee welcomed the Government’s use of ILO technical assistance to improve labour inspections. The Committee noted with concern the current practice of moratoriums on labour inspections in the country and the restrictions on the powers of labour inspectors.

Taking the discussion into account, the Committee urged the Government, in consultation with the social partners, and in line with the Conventions, to take effective and time bound measures to:

• eliminate the temporary ban on inspections and refrain from reintroducing such bans in the future;
• recruit labour inspectors and provide them with material, financial and operational resources in order to ensure the proper functioning of the Labour Inspectorate;
• ensure that labour inspections are undertaken as often and as thoroughly as necessary, including by ensuring that all the restrictions on the Labour Inspectors’ powers are removed;
• ensure that effective and adequate enforcement and penalties are in place, by ensuring that labour inspectors have the power to exercise their discretion to give warning and advice, instead of instituting or recommending proceedings, and establishing adequate penalties for obstructing labour inspectors in the performance of their duties.

The Committee invited the Government to continue availing itself of ILO technical assistance in this regard.

The Committee requested the Government to provide detailed and complete information to the Committee of Experts on measures taken in line with the Conventions by 1 September 2025.

Chairperson – I have the honour to give the floor to the distinguished representative of the Government of Uzbekistan, the Minister of Employment and Poverty Reduction.

Interpretation from Russian: Government representative – We would like to express our gratitude to the Committee of Experts and this Committee for the conclusions. The Government of the Republic of Uzbekistan would reaffirm its full commitment to implementing the ratified Conventions and its preparedness to continue working to ensure the effectiveness of labour inspection. We will look very closely at all of the recommendations, strengthen cooperation with the ILO and take the necessary measures to eliminate the problems that have arisen.

Individual Case (CAS) - Discussion: 2025, Publication: 113rd ILC session (2025)

Labour Inspection Convention, 1947 (No. 81); Labour Inspection (Agriculture) Convention, 1969 (No. 129)

Written information provided by the Government

The Government has provided the following written information, as well as a copy of the 2024 labour inspection report (in Uzbek).

Upon reviewing the Committee’s request, the Ministry of Employment and Poverty Reduction notes that, pursuant to article 534 of the Labour Code, State control and supervision over compliance with labour legislation and occupational health and safety rules are exercised by the State Labour Inspectorate (SLI). As a structural subdivision of the Ministry, the SLI monitors and supervises employers’ compliance with labour laws, legislation on employment, compulsory insurance of employers’ civil liability, the rights of persons with disabilities, and other labour-related legal acts, health and safety regulations, and labour standards.

Chapter 33 of the Labour Code sets forth the procedure for monitoring and supervising compliance with labour legislation and occupational health and safety rules. Additionally, article 22 of the Law on the Prosecutor’s Office stipulates that, in the process of exercising oversight of the implementation of laws, prosecutors may request inspections by various Government bodies and the allocation of specialists to conduct departmental or interdepartmental inspections. In the context of the SLI, this means that labour inspectors may be involved in unplanned inspections initiated by law enforcement or oversight bodies if there are grounds for violations of labour rights or occupational safety rules. The SLI itself conducts both scheduled and unscheduled inspections to enforce labour legislation and occupational safety standards. These inspections not only assess legal compliance, but also verify whether employers have rectified violations previously identified by inspectors. Currently, there are no time restrictions on the duration of inspections carried out by labour inspectors. In 2018, the Government introduced a two-year moratorium (until 2020) on inspections of the financial and economic activities of business entities, aimed at accelerating economic development and promoting entrepreneurship. It is noteworthy that this moratorium did not apply to inspections conducted by the SLI.

Paragraph 4 of Presidential Decree No. PP-3913 of 20 August 2018 on measures to improve the structure of labour bodies and strengthen the system of protection of labour rights and occupational safety provides that the SLI shall conduct consultations with authorized bodies based on applications from individuals, legal entities or the tax service. The right to carry out unplanned short-term (up to one day) inspections of compliance with labour and occupational safety legislation without prior approval remains with the SLI. Moreover, under the Presidential Decree on measures to improve and enhance the effectiveness of State policy in the sphere of employment and poverty reduction, the requirement to obtain permission from the business ombudsman for conducting inspections was abolished in October 2024. Currently, electronic notification is sufficient.

In addition to inspections conducted with prior notification, Presidential Decree No. PP3913 mandates scheduled and unscheduled inspections in all organizations, regardless of ownership type. For example, during the cotton harvest in 2024, inspections were conducted without prior coordination with the competent authorities. Over 300 inspectors were involved in monitoring around 25,505 organizations, farms and cotton fields across the country to prevent forced labour and ensure decent working conditions. These inspections uncovered 520 violations, including 238 (46 per cent) related to poor working conditions, 102 (20 per cent) due to the absence of labour contracts and 180 (34 per cent) due to delayed wage payments. As a result, written instructions were issued to the heads of 330 farms, and administrative penalties were imposed on 23 officials under article 49(1) of the Administrative Offences Code (violations of labour and occupational safety legislation by officials).

The SLI operates in accordance with the Law on Appeals of Individuals and Legal Entities (new version dated 11 September 2017, No. ZRU-445). Article 19 prohibits the disclosure of private information or data that violates the rights or interests of citizens and legal entities, unless consent is given. Upon request, a complainant’s identity must not be disclosed. In 2024, the SLI received 27,166 appeals, of which 16,181 were upheld and 8,948 were clarified; 12,472 citizens had their labour rights restored. Additionally, 390 appeals were submitted to the business ombudsman and led to inspections of business entities – all of which were upheld.

Throughout 2024, the SLI conducted 18,807 control activities related to labour and occupational safety legislation, identifying 49,488 violations. As a result, 10,556 written orders and 435 mandatory representations were issued, and penalties were imposed on 8,281 officials. Of the 49,488 violations, 31,839 concerned labour rights violations, including: 5,844 – failure to provide leave; 4,542 – non-payment of wages; 2,022 – absence of employment contracts; 672 – informal employment; 2,172 – violations of employment legislation; 776 – unlawful dismissals; and 1,478 – violations of labour record procedures. A further 17,649 violations pertained to occupational safety and unsatisfactory working conditions, including: 3,047 cases of employees working without safety instruction; 2,198 cases of lack of safety training and certification; 1,194 cases of absence of protective clothing and equipment; 1,466 cases of lack of occupational safety plans; 844 enterprises with no medical examinations; 991 without established occupational safety services; and 551 without workplace condition certification. In 2024, 717 unlawfully dismissed workers (including 341 women) were reinstated, and assistance worth 75 billion Uzbek sum was provided to 9,970 individuals. There were 868 occupational accidents in 2024 involving 974 people: 261 fatalities, 683 serious injuries, and 30 minor injuries. Over 3.7 billion sum was paid in compensation to affected workers or their families.

The SLI may involve technical experts, including medical, electrical, chemical and engineering specialists, in inspections. While such experts have not yet been engaged, an expert working group exists within the SLI. The SLI maintains records as stipulated in Article 21 of Convention No. 81, and Article 19(1) and Article 27 of Convention No. 129, based on data submitted by employers through the interdepartmental Unified Labour System database (also available at dmi.mehnat.uz). According to Cabinet of Ministers Resolution No. 286 of 6 June 1997, all workplace accidents must be reported within three working days, analysed by the employer, and discussed with the workforce to prevent recurrences.

Article 26 of the Law on Occupational Safety requires the investigation and registration of occupational diseases, with procedures established for cooperation between employers, medical institutions and the SLI. Employers must notify the SLI of all occupational illnesses and corrective measures taken.

To improve transparency and efficiency, the Ministry is digitalizing SLI operations. The Unified Labour System will soon enable simplified procedures for handling violations, allowing inspectors to issue penalties electronically. A risk analysis system has also been introduced, using 13 criteria to assess risk levels without human involvement. Organizations with high or medium risk are audited automatically, and integration of this system with the Unified State Control System is under way.

Presidential Decree No. PP-347 of 4 April 2024 increased SLI staff by 16 per cent, from 345 to 412, including an increase in central staff from 17 to 22. All SLI staff were fully certified between February and March 2025, with several employees sent for retraining. Under Cabinet Resolution No. 246 of 27 April 2017, technical inspectors must undergo at least 36 hours of occupational safety training annually.

Article 249 of the Labour Code states that wage systems for public employees are determined by law. Article 252 provides that the rules for incentive payments are also set by legislation. The Ministry relies on these regulations when determining salary scales. Currently, the average inspector’s salary is 8–10 million sum. Positions in the State Tax Committee and Ministry of Internal Affairs are classified two grades below that of labour inspectors, making labour inspector salaries more competitive. According to Cabinet Resolution No. 424 of 2 August 2022, employees are reimbursed for travel, accommodation and per diem expenses while on official trips. As per paragraph 39 of the SLI Regulations (Appendix 3 to Cabinet Resolution No. 1066 of 31 December 2018), inspectors receive monthly bonuses of up to 10 per cent of fines collected, not exceeding 35.15 times the minimum wage. This system incentivizes impartial inspections.

Regarding trade union inspections, article 540 of the Labour Code grants trade unions the right to conduct public monitoring of labour legislation and collective agreements. They may examine workplace safety at various stages of a project, participate in investigations into accidents, attend expert medical commissions, and engage in dispute resolution and legal actions on behalf of workers. Unions may establish their own inspection services. Information collected by these inspectors is compiled and published on official union websites. As of 2025, 116 union inspectors are employed across the Federation of Trade Unions and its branches (9 women, 107 men). Their qualifications include those of lawyers, engineers, doctors, economists and other professionals. There are fundamental differences between the SLI and trade union inspectors: the SLI has legal authority to inspect all entities, impose penalties and produce official reports, while trade union inspectors operate within a limited membership scope and have no legal enforcement powers. Nonetheless, both systems complement one another within the framework of tripartism and social dialogue.

Currently, the ILO project entitled Improvement of Labour Inspection and Occupational Safety Systems in Uzbekistan (October 2024–December 2025) is being implemented. The Government would appreciate further ILO support in implementing Conventions Nos 81 and 129, and in enhancing the capacity of Ministry staff in reporting and Labour Inspectorate operations.

Discussion by the Committee

Chairperson – I have the honour to give the floor to the distinguished representative of the Government of Uzbekistan, the Minister of Employment and Poverty Reduction, for his opening statement.

Interpretation from Russian: Government representative – To begin with, I would like to thank the Committee for giving us the opportunity to share with you some information on the work that we have been doing in Uzbekistan, in order to implement Conventions Nos 81 and 129. Obviously, both Conventions are of key importance for guaranteeing workers’ rights, including such issues, as freedom of association and collective bargaining, as well as reducing the scale of informal employment and expanding opportunities for decent work.

Uzbekistan has ratified all fundamental and ILO governance Conventions and has demonstrated itself to be a partner capable of fulfilling its commitments in terms of their implementation.

We can go back a few years and recall that previous questions to Uzbekistan about systematic forced and child labour have been left behind. Uzbekistan is actually an example for demonstrating firm political will and for carrying out comprehensive reforms that have led to the complete eradication of these phenomena.

I would like the achievements that we have made to remain in the memories of the members of the Committee and to serve as a basis for trust, now and in the future, in our Government, that the other obligations that we have to comply with in relation to international labour standards will be fulfilled.

Uzbekistan has achieved considerable progress in laying down a legal and practical basis for implementing labour rights.

In 2019, we ratified Conventions Nos 81 and 129, but even before ratification, we carried out the first reform of our labour inspection system in 2018. We set up one single State Labour Inspectorate in April 2023. We brought into force a new Labour Code, which was developed with the support of ILO, World Bank and other partners. The Labour Code outlaws child and forced labour, enshrines the basis for collective bargaining, and aims at improving employment.

What is equally important is that the Government has taken decisions in respect of digitalization, which will enhance both the effectiveness and the transparency of the Labour Inspectorate.

I would like to go into further details on the changes which have taken place in Uzbekistan since the first report on these Conventions was submitted, so that the distinguished members of the Committee and the other Members of the ILO at this meeting can learn about the reforms and the challenges to which our Government is still trying to react.

First of all, the Committee of Experts appealed to us to withdraw the moratorium on the work of the Labour Inspectorate, noting that labour inspection should be able to be independent. It was put in place by a Government decision in 2018, in order to speed up economic development and promote entrepreneurship. It applied to the financial and economic activities of companies and enterprises, and later a procedure for obtaining permission from the business ombudsman to conduct inspections was introduced for labour inspections.

The Labour Code, which came into force in April 2023, establishes a free system for monitoring and supervising compliance with labour legislation and occupational safety rules. It has a greater legal force than the decision of the Government and, therefore, has removed the moratorium.

As part of institutional reform, in September 2024, the Presidential Decree on measures to improve and enhance the effectiveness of State policy in the sphere of employment and poverty reduction was adopted, formally abolishing the procedure for obtaining permission from the business ombudsman.

Now the Labour Inspectorate can carry out announced and unannounced inspections and there are no limits on the length of the inspection. The Labour Inspectorate can also hold consultations and inspect employers on the basis of information from legal and physical persons, the Prosecutor’s Office, the tax service and others.

The first stage of the digitalization of the Labour Inspectorate has been completed: a unified database has been created, which works in conjunction with the Unified Labour System and the Digital Tax Platform. Inspectors now have access to information about all registered companies and organizations and about all taxpayers, including those involved in what we describe as non-traditional forms of employment, that is, freelance workers, short-term workers, and people working on digital platforms, etc. The inspectors also have access to all labour contracts in this newly digitalized system.

There is also a rating of employers based on risk assessments of the possibility that they may commit any kind of infringement of the labour law.

At the moment, the practice of informing the business ombudsman for scheduled inspections is still in place. However, unscheduled inspections are carried out without prior notification.

Now there are two things I would like to mention. During the cotton harvest, which is the most sensitive sector in respect of labour issues in Uzbekistan, inspections are carried out without announcement, and with the involvement of inspectors from other organizations, such as medical professionals or health service officials.

Every year the ILO continues to cooperate with us in training inspectors, nongovernmental organizations and civil activists and guaranteeing independent monitoring of the situation in that area.

The practice of registering other inspections in the Unified Inspection Database and notifying the business ombudsman has been introduced to combat corruption. That is the first point I wanted to make.

Now, the second point brings me to where the Committee of Experts requested statistics about the quantity of inspections carried out with the authorization of the business ombudsman and those carried out as a result of complaints, as well as the quantity of requests for inspections and the number of cases where authorization was refused. From statistics, we can see that the number of inspections started by the inspection service itself has been going up every year. In 2023, the number was 920. By 2024, we were talking about a doubling of that figure and we had approximately 2,000 inspections. In five months of this year, the quantity of inspections started by the Labour Inspectorate itself exceeded 3,000. So, what we see is a positive trend. There is an increase in such inspections. The business ombudsman now has no way of influencing whether an inspection is carried out or not as a result of the changes made in October 2024.

The Committee of Experts also asked about the nature and number of violations identified during inspections, judicial proceedings and subsequent sanctions imposed, including their amounts. I will take the first five months of this year as an example. From January to May, 7,840 inspections were carried out and 15,512 infringements were detected. 3,655 warnings were issued, and if I am not mistaken, administrative fines were levied on 4,368 individuals.

The fourth question which was asked was the number of inspectors in the State Labour Inspectorate. After carrying out our institutional reforms, the number of inspectors increased from 380 to 412. Of course, we understand that this figure is not yet sufficient to fully cover and monitor compliance with labour legislation. Therefore, we are in the process of undertaking new reforms which will be brought into operation in the near future, and we hope that before the end of this year, the number of inspectors will have increased by a minimum of 100.

The fifth point raised by the Committee of Experts was the issue of labour inspections carried out by trade unions. Trade unions do have the right to what we call “social control”, which means that they can contact employers and submit representations to them regarding the elimination of violations of labour legislation or occupational safety rules, apply to the State Labour Inspectorate, and also to the courts in defence of the labour rights of workers. There are key differences however, between the functions of the State Labour Inspectorate and the inspectorate run by trade unions. The State Labour Inspectorate has, of course, the authority of the State behind it and can carry out checks and inspections in any enterprise or office. It can also apply administrative sanctions and hold employers responsible for infringements to legal responsibility. The inspection service run by unions carries out social control, does not have the same level of authority, and cannot apply sanctions. However, both systems complement each other and are part of our system of tripartism and social dialogue.

In conclusion, we do realize that we still have challenges that have to be met and problems that have to be overcome. We do know the situation in Uzbekistan is not perfect in respect of our compliance with our own labour legislation or international labour Conventions. However, this meeting has, in the past, been a platform for tripartite dialogue and a healthy exchange of opinions and, indeed, it offers an excellent opportunity for multilateral cooperation. It also helps all of us to meet the challenges we face. Therefore, believing in the spirit of cooperation, in order to achieve full implementation of the obligations under Conventions Nos 81 and 129, we request technical assistance from the ILO in addressing the remaining issues. First of all, it concerns assistance, and I will try to do this briefly, for improving our labour inspectorate system, strengthening labour inspection capacity, expanding trilateral dialogue, integrating labour policy into sustainable development, a communication strategy for labour inspection, and following ILO recommendations.

Worker members – It cannot be repeated too often: inspection services are essential to ensuring the effectiveness of rights and compliance with rules in the world of work. They are a vital public service, playing a central role in promoting decent working conditions and fundamental principles and rights at work.

To fulfil this mission, inspection services must be provided with an adequate legal framework and human, material and financial resources commensurate with the importance of their mission. Unfortunately, we are bound to observe that they do not benefit from all these guarantees in Uzbekistan.

As in other countries in the region, it is common to see a moratorium imposed on inspections. We have already seen this with Kyrgyzstan, and it is also the case in Uzbekistan. Such a moratorium was recently imposed on the financial and economic activities of establishments, with the exception of inspections carried out in the context of criminal cases or in connection with the liquidation of a legal entity. We understand that this moratorium has ended in the meantime, in December 2024. Under the moratorium, the only possibilities for the inspection services to intervene seemed to be in cases where a complaint was lodged with them. We can only support the conclusion of the Committee of Experts, which points out that a moratorium imposed on labour inspection constitutes a serious violation of the Conventions.

In addition, labour inspectors are subject to numerous restrictions in the course of their activities. A Presidential Decree of 15 March 2019 sets out the following restrictions:

• All inspections must be registered electronically.
• Any inspection carried out without such registration is illegal.
• The Commissioner for the protection of the rights and legitimate interests of business entities coordinates inspections and ensures that they are carried out in accordance with the law.
• The electronic inspection registration system allows the Commissioner to examine the validity of the authorities’ decisions to carry out inspections and issue a permit with a unique code for their implementation; and to verify that the authorities comply with the inspection procedure defined by law. It also allows business entities to receive, upon request, information about the inspection in the form of short messages (SMS), as well as via the internet in real time.

The same Presidential Decree also limits the duration of inspections. Another Presidential Decision of 2018 limits inspections in response to a complaint to one day, and also limits the scope of these inspections.

A Presidential Decree of 13 September 2022 contains further restrictions on the powers of inspectors. It sets out an endless list of restrictions:

• Inspectors are required to notify a business entity that an inspection will take place at least 10 working days in advance.
• Inspectors are not allowed to carry out re-inspections.
• Business entities have the right to refuse inspections if the order to carry out the inspection has not been issued in accordance with the established procedure or if the notification period for the inspection has not been respected.
• Inspections may only be carried out after preventive measures have been put in place.
• Inspectors must submit a request for approval to the Commissioner.
• The Commissioner also has the right to refuse inspections.

This Presidential Decree also stipulates that:

• The inspection order must contain the subject of the inspection, its duration, and the period of activity subject to inspection.
• During the inspection, officials of the supervisory authority must not exceed the specified time limit, the scope of their powers, and the issues defined in the inspection programme.
• Before starting an inspection, the inspector must inform the head of the business entity of the purpose of the inspection, present an official identity document authorizing the inspector to conduct the inspection, and provide copies of the documents that are the basis for the inspection.
• Lastly, inspections may only be carried out during working hours.

As you will agree, this Presidential Decree alone contains an impressive series of restrictions that are contrary to the Convention and do not facilitate the work of labour inspectors.

As if the list of restrictions was not long enough already, there are others restrictions to add. Workplaces that obtain certification through occupational safety and health audits cannot be subject to any planned inspection for three years.

The State Labour Inspectorate regulations, which define the powers of inspectors, omit important prerogatives that should be part of these powers. They are not empowered to question witnesses, employers or workers, or to take or remove, for analysis, samples of materials and substances used or handled.

In accordance with the Occupational Safety Act and the State Labour Inspectorate Regulations, when violations of the law are detected, labour inspectors are first required to issue an order to address the violations and take preventive measures. Only in the event of non-compliance with the order may inspectors consider administrative penalties on the basis of the Administrative Liability Code. However, inspectors themselves are not empowered to impose administrative fines. It is a court that must decide on the basis of the evidence provided by the inspectors.

These elements are not in conformity with the provisions of the Conventions, which provide that the decision to issue warnings or advice rather than initiate proceedings must be left to the discretion of labour inspectors.

Finally, the Committee of Experts’ report notes that the Labour Code provides that obstruction of labour inspectors in the performance of their duties may entail liability for the perpetrators, but does not provide for any penalties for such violations.

After listing these breaches of the Conventions under examination, you will understand that we share the deep concern expressed by the Committee of Experts in its report. All these factors are likely to seriously hamper the work of the inspection services in Uzbekistan.

We hope that the Government will engage in constructive dialogue with our Committee and all the ILO bodies concerned in order to follow up on the recommendations made to it and thus remove the many restrictions that place an unfair burden on the inspection services.

Employer members – The Employer members thank the Government of the Republic of Uzbekistan for their oral and written information on this case. The Employer members emphasize the importance of the Government’s compliance with Conventions Nos 81 and 129. These are governance or priority Conventions, as such they require special attention because of their importance for the functioning of the international labour standards system.

We would like to start by providing some background information and context. The Republic of Uzbekistan joined the ILO in 1992. It has ratified a total of 25 Conventions and one Protocol. This includes all ten fundamental Conventions, all four governance Conventions and 11 technical Conventions. The Republic of Uzbekistan ratified Conventions Nos 81 and 129 on 19 November 2019.

The Committee of Experts previously adopted an observation on the Government of the Republic of Uzbekistan’s application of Conventions Nos 81 and 129 in 2024. The Committee of Experts also previously made two direct requests to the Government of the Republic of Uzbekistan on the application of Conventions Nos 81 and 129. This year is the first time that the Committee has examined the Government of the Republic of Uzbekistan’s application of Conventions Nos 81 and 129.

The Government of the Republic of Uzbekistan has been going through a process of significant reforms to transition to a market economy. In the past few years, the Government has been working with the ILO to improve labour inspections and occupational health and safety systems in the country. However, significant gaps still exist.

The Committee of Experts’ comments relate to three issues regarding the Government’s application of Conventions Nos 81 and 129.

First, the Committee of Experts noted with deep concern that there is a temporary moratorium on labour inspectors imposed by law.

Second, the Committee of Experts noted with deep concern the extent and gravity of several measures imposed by law, restricting the ability and authority of inspectors to conduct labour inspections.

Third, the Committee of Experts noted deficiencies in the enforcement and penalties provisions in relation to labour inspections.

With respect to the first issue, the Employer members note that Article 16 of Convention No. 81 and Article 21 of Convention No. 129 state that workplaces shall be inspected as often and as thoroughly as is necessary to ensure the effective application of the relevant legal provisions.

The Employer members note the Committee of Experts’ deep concern that there is a temporary moratorium on most inspections imposed by Presidential Decree.

The Government provided information, noted in the Committee of Experts’ report, that the State Labour Inspectorate has the right to initiate an inspection within the framework of the issues raised in the complaint, notwithstanding the moratorium.

The Government also provided additional information on 20 May 2025 to the Office, disputing the existence of a moratorium on labour inspection and stated that there was an issue regarding the interpretation of the Presidential Decree imposing that moratorium. The Employers underscore the importance of ensuring that workplaces are inspected to safeguard the effective enforcement of legal provisions. As noted by the Committee of Experts in its general observation adopted in 2019 on Convention No. 81, a modern, well-designed and riskbased approach to labour inspection planning is compatible with Conventions Nos 81 and 129.

With respect to the second issue, the Employer members note that Article 12 of Convention No. 81 outlines the various powers to be granted to labour inspectors. These include the power to enter workplaces without prior notice. It also includes the power to carry out an examination, test or inquiry, including interrogating the employer or their staff on any matters concerning the application of legal provisions. Article 16 of Convention 129 includes similar provisions.

The Employer members note the Committee of Experts’ deep concern that the law by Presidential Decree contains a number of restrictions to the power of labour inspectors. These include the following:

• a requirement that labour inspectors obtain prior approval of inspections by an authorized body which can also refuse to provide approval in certain circumstances.
• during the inspection, inspectors are barred from going beyond the timeline and the scope of their powers and issues defined by the order of the authorized body.
• labour inspectors can only conduct inspections after preventive measures have been implemented.
• labour inspectors must provide prior notification to a business entity of the commencement of a labour inspection.
• business entities have the right to refuse inspections in certain circumstances.

Finally, the Employer members note the Committee of Experts’ observation that the regulations on the State Labour Inspectorate does not include the power to question alone or in the presence of witnesses the employer or its staff on matters concerning the application of legal provisions. They also do not have the power to take or remove for purposes of analysis samples of materials and substances.

In order to ensure the effectiveness of the governance of labour standards and the application of labour standards in law and in practice, the Employer members emphasize the importance of providing labour inspectors who hold the proper credentials with the powers outlined in Conventions Nos 81 and 129.

With respect to the third issue, the Employer members note that Article 17 (2) of Convention No. 81 states that it should be left to the discretion of labour inspectors to give warning and advice instead of instituting or recommending proceedings. Article 22 (2) of Convention No. 129 contains a similar provision.

Moreover, Article 18 of Convention No. 81 states that national laws or regulations must provide for adequate penalties for violations of the legal provisions and for obstructing labour inspectors in the performance of their duties. Article 24 of Convention No. 129 contains a similar provision.

The Employer members note the Committee of Experts’ observation that, under the applicable Occupational Safety Act and the regulations on the State Labour Inspectorate, when violations of the law are detected, labour inspectors will first issue an order to take preventive measures. The Employer members also note the Committee of Experts’ observation that the Labour Code establishes liability for the obstruction of labour inspectors. However, it does not specify any sanctions for such a violation.

The Employer members urge the Government of the Republic of Uzbekistan to comply with the effective enforcement and adequate penalties provisions of Conventions Nos 81 and 129. In order to ensure the effectiveness of the governance of labour standards and the application of labour standards in law and in practice, there must be an effective enforcement mechanism which includes adequate penalties. Issuing orders to take preventive measures must also be coupled with instituting or recommending proceedings. Furthermore, there should be sanctions for parties who obstruct the work of labour inspectors.

In conclusion, the Employer members strongly urge the Government of the Republic of Uzbekistan to commit to meeting the requirements of Conventions Nos 81 and 129 both in law and in practice.

Interpretation from Russian: Worker member, Uzbekistan – It is an enormous honour to speak today on behalf of the Federation of Trade Unions of Uzbekistan (FPU). Bearing in mind that Uzbekistan has ratified Conventions Nos 81 and 129 concerning the work of the Labour Inspectorate, normative and legal acts and laws in our country should be brought into accordance with the requirements of those Conventions. They are also supposed to be applied in practice. That is a priority for our Federation and it is something that we have brought up at tripartite consultation meetings more than once.

We are grateful to the Committee of Experts for having gone into detail into the situation with respect to the application of the Conventions in practice. We note that, with ILO support and the participation of tripartite partners, we have already carried out a comprehensive overhaul of the activity of the State Labour Inspectorate.

In autumn 2024, the Government decree lifted the moratorium on inspections. This is a positive step forward. We hope that further steps will follow, so that the work in Uzbekistan will lead to compliance with these Conventions in practice.

On its side, the FPU, in order to exercise public control over compliance with regulatory and legal documents relating to the socio-economic rights and interests of workers, as well as regulatory documents in the field of technical regulation, on the basis of the Law on trade unions, set up in 2020 a Labour Inspectorate within the FPU.

We had 50 inspectors at first. We now have over 100 inspectors working across the union at local, branch and regional levels. The inspectors not only find infringements and advise on how to tackle them, they also carry out awareness-raising activities among workers, informing them about their labour rights and occupational safety.

During the period in which they have been working, they have carried out 3,520 educational and awareness-raising events. They have also held seminars and webinars with unionized workers, so as to enhance their knowledge and skills. We hope this work will lead to preventing infringements, saving lives and protecting the health of workers and also change the culture of labour relations in the workplace.

On the basis of a monitoring plan for workers’ rights and the establishment of decent work, which was developed by the Ministry of Employment and Poverty Reduction, the FPU and the Confederation of Employers in our country conduct monthly checks and investigations in various branches of the economy.

The workers of the Labour Inspectorate have participated actively in the national monitoring of conditions in the cotton harvest, in particular to prevent child and forced labour during the harvesting season. The FPU also organized a system of feedback so that it could work constantly on this issue.

Of course, we still recognize that we have challenges to meet, particularly in fully implementing the provisions of Conventions Nos 81 and 129 on the effectiveness and independence of the Labour Inspectorate, including in agriculture.

The unions of Uzbekistan believe that an effective and independent system of labour inspection is of decisive importance for ensuring compliance with labour rights and improving working conditions. We think there are key challenges we have to address, which arise in our national labour market and which have a direct influence on the possibility of the Labour Inspectorate to carry out its work properly.

Firstly, in our country we still have a very high level of informal employment, especially in agriculture, construction, small business and the services sector. It is thought that the vast majority of workers are not covered by active labour contracts. They are not registered in the official system and, as a result, they are deprived of their basic social and legal protection. This limits significantly the ability of the Labour Inspectorate to carry out monitoring and requires a review of the methods used to cover the informal sector.

Secondly, labour migration remains a major issue for us, especially with Uzbek citizens leaving to work abroad. Quite often, the rights of these migrants to decent working conditions and labour protection, as well as safety in the workplace, are not guaranteed.

We appeal for more international cooperation in the area of labour inspection, including through bilateral agreements, exchange of information and coordination between the labour inspectorates of different countries.

Thirdly, the Labour Inspectorate in Uzbekistan comes up against problems of an institutional nature. That means a lack of inspectors, insufficient provision of equipment and a lack of training for officials. Quite often, the inspectors do not have sufficient access to industrial sites, or they suffer pressure exerted by employers, particularly in the private sector. This undermines trust felt by the workers in the fact that their rights will be protected.

Furthermore, as we digitalize the economy and as non-standard forms of employment spread, such as working freelance, temporary contracts and platform work, there is a need to adapt the mechanisms of our Inspectorate.

Law and inspection practices should take into account the new realities in the world of work and protect the rights of all workers, whatever the form of employment they are engaged in.

In conclusion, let me underscore that strengthening the Labour Inspectorate is impossible without the full development of social dialogue. Unions should be actively involved in the process of monitoring conditions at work, provide information on violations and also be involved in developing decisions and strategies at all levels. We insist on the need for regular participation of unions in the action of the Inspectorate, including in carrying out joint inspections and risk assessments.

We believe that the effectiveness of the State Labour Inspectorate should be determined by the number of violations prevented, the amount of lives saved, and the growth of understanding by workers and by employers of their rights, rather than by formal reporting on investigations of violations that have already occurred.

In this regard, we request further technical assistance from the ILO, including expert support, training for inspectors, development of methodological materials and assistance in the institutional development of inspection bodies.

We are convinced that, with the ILO’s support and through active social dialogue, we will be able to improve the monitoring of labour rights and ensure decent working conditions for all the workers of Uzbekistan.

Interpretation from Russian: Employer member, Uzbekistan – I would like to make one or two comments on the topic under discussion today. The Employers of Uzbekistan consider that we need to first of all, increase the transparency, independence and status of the State Labour Inspectorate in Uzbekistan. As we see it, a strong inspection service is a guarantee of fair, honest and high-quality control.

As employers, we note that the inspection service participates actively in tripartite dialogue and in bilateral cooperation with our Employers’ confederation.

As an example, let me say that the inspectorate always actively cooperates with our organization and it has been an active participant in events that we have held.

At the beginning of this year, for example, it started to participate in meetings with us and, so far, it has participated in six meetings which have looked at the work of the Labour Inspectorate and at the problems with its work that we have identified.

At the same time, the current rules governing the State Labour Inspectorate in its work are not fully in accordance with Convention No. 81, which, as we know, was ratified by the Republic of Uzbekistan in 2019.

We would like to draw your attention, with your permission, to several challenges that we see:

• First of all, it is an institutional challenge, by the simple fact that we do not have sufficient numbers of labour inspectors in our country.
• Secondly, and because of that, each inspector has far too much work to do. The result of that is that they do quick and superficial inspections and that leaves us a bit doubtful about the outcome and the conclusions.
• Thirdly, there is a system of bonuses for labour inspectors in Uzbekistan, which is based on a percentage of the amount levied as fines. This is still operating and we fear that this does not really enhance trust among employers, the kind of trust we would like to have in the conclusions reached and the measures taken.
• We think that the Labour Inspectorate should be the only body responsible for carrying out inspections in our country, but as my colleague, I think, indicated, there is what is described as a trade union inspectorate that carries out what is known as social control. It is true that this service does not have the possibility of giving fines or other punitive measures, but according to Convention No. 81, labour inspection at companies and in industries and agriculture is supposed to be carried out only by a State body. This worries us as employers, and we think it undermines both the independence and the transparent status of the State Labour Inspectorate.
• Furthermore, there are not sufficient numbers of inspectors in Uzbekistan who are trained in carrying out inspections at more specialized enterprises.

If inspectors do not have the necessary qualifications, they cannot do a proper job. Each sector of the economy has its own characteristics, its own features and inspectors have to know the method to carry out inspections correctly.

What measures do we think are necessary to deal with this situation?

Well, firstly, there has to be an increase in the numbers of labour inspectors in Uzbekistan. That is extremely important.

We also agree that something needs to be done, and here I agree with my colleague about the system of bonuses for inspectors, because that really is a problem for us. We would like that to be changed. We heard our colleagues mention this, too, that the imposition of fines and the handing down of punitive measures is an issue.

I mentioned the system of inspections in the FPU. We would prefer to suggest a change of name for that. We could call it something like the “social monitoring service”, but not the “Labour Inspectorate”, so that we do not have this issue of confusion between that body and the work of the State Labour Inspectorate. It simply causes confusion and also leads to a reduction in the authority of the State Labour Inspectorate. We would like the Labour Inspectorate to be working in partnership with the employers of Uzbekistan and not to be seen as a body whose purpose is punitive.

We do understand also that there is a need to do preventive work, which means better cooperation between business and the Labour Inspectorate to ensure that the law is observed and to minimize infringements, infractions and violations in the first place.

Lastly, the employers of Uzbekistan and, indeed, our Uzbek colleagues from the Union, believe it is absolutely correct that the employers of Uzbekistan would like to be observers when State inspections are carried out, so that we can guarantee that what is being done is both correct and transparent. I mentioned transparency at the beginning, and it is very important to us in every sense. It is equally important to us that our rights and duties as employers in Uzbekistan are governed by the law and that the law in respect of the Labour Inspectorate is properly observed.

Let me say in conclusion that, of course, we are unable to achieve any of this without the technical support and advice of the ILO. As employers in Uzbekistan, I would like to echo the call for support to Uzbekistan in general and to the employers’ organization in Uzbekistan, so that we can all work together to improve our mechanisms through tripartite dialogue and thereby, enhance the quality of the Uzbek Labour Inspectorate and its work. We do think that a strong Labour Inspectorate, as I said, is a guarantee of many things, including economic growth, but only if it works equally and impartially with the employer’s organization, the unions and the Government. We want a balanced system which does not lurch in favour of, or against, one side or the other. If we obtain that, then we’ll be heading in the right direction.

Government member, Poland – I have the honour to speak on behalf of the European Union (EU) and its Member States. The candidate countries, Albania, Montenegro, North Macedonia, Republic of Moldova and Ukraine, and Norway, member of the European Economic Area align themselves with this statement.

The EU and its Member States are committed to the respect, protection and fulfilment of human rights, including labour rights.

We promote the universal ratification and effective implementation of fundamental ILO Conventions and support the ILO in developing and promoting international labour standards and supervising their application.

Labour inspection as provided for in Convention No. 81 is key in promoting and safeguarding decent working conditions.

In 2021, Uzbekistan became a beneficiary of a special incentive arrangement for sustainable development and good governance of the EU generalized scheme of preferences, the GSP plus, which, in addition to generous market access, offers a platform to exchange on and promote sustainable development based on Uzbekistan’s commitment to the effective implementation of 27 international Conventions, particularly on human rights, including labour rights and environmental protection and climate change and good governance. Moreover, the EU and Uzbekistan concluded negotiations in 2022 on an enhanced partnership and cooperation agreement which aims to extend their relationship into new areas of cooperation.

Lastly, the EU supports Uzbekistan’s reform agenda through technical and financial assistance, including concerning labour rights. The moratorium placed on labour inspection in force since September 2018 is a serious violation of Conventions Nos 81 and 129.

We note with deep concern that at present no scheduled inspections are conducted in business entities due to this moratorium on inspections of the financial and economic activities of business entities.

In line with the Committee of Experts’ recommendation, we urge the Government to eliminate the temporary ban on inspections and to ensure that labour inspectors are able to undertake labour inspections as often as necessary to ensure the effective application of the Conventions.

Furthermore, we note with deep concern the extensive restrictions on labour inspections. We appeal to the Government to take the necessary measures to ensure that labour inspectors are not limited in their work.

They must be empowered to make visits to workplaces liable to inspection without previous notice, to carry out any examination, test or inquiry which they may consider necessary, to choose not to notify the employer or his representative of their presence and to undertake labour inspections as often and as thoroughly as it is necessary.

We also recall the importance of ensuring that labour inspectors treat as absolutely confidential the source of any complaint and give no intimation to the employer that an inspection was made in consequence of such a complaint.

Lastly, labour inspectors should be empowered to ensure effective enforcement and adequate penalties such as administrative fines. We reiterate the Committee of Experts’ call to introduce sanctions for cases of obstruction of labour inspectors in the performance of their duties. In this context, we welcome the implementation of the Decent Work Country Programme 2021–25. We also welcome the implementation of the ILO project on the improvement of labour inspection and occupational safety systems in Uzbekistan in 2024–25.

We thank the Office for its active engagement in the promotion of labour rights and welcome the fact that Uzbekistan avails itself of ILO technical assistance.

We took note of the written information provided by the Government of Uzbekistan, including the rationale that the moratorium introduced on inspections of the financial and economic activities of business entities was aimed at accelerating economic development and promoting entrepreneurship.

We encourage the Government to provide further information related to the practical application of Conventions Nos 81 and 129, in order to respond to the Committee of Experts’ requests.

The EU and its Member States stand ready to support Uzbekistan with the aim of strengthening the Government’s capacity to address the issues raised and in meeting its obligations under the ratified Conventions. We will continue to follow closely the situation in the country.

Government member, Cuba – Cuba acknowledges the positive progress made by Uzbekistan in implementing the ILO Conventions on labour inspection, specifically Conventions Nos 81 and 129. Since the ratification of the Conventions in 2019, Uzbekistan has worked actively to strengthen its State Labour Inspectorate, ensuring compliance with labour and occupational safety legislation in all sectors, including agriculture.

The country has implemented a more efficient and transparent inspection system, with planned and unplanned inspections that verify compliance with labour standards and the rectification of previously identified violations. In the agricultural sector, the labour inspection entity has intensified its supervision to prevent forced labour and improve working conditions, especially during the cotton harvest. In addition, it has introduced digital tools to optimize labour inspection. The risk analysis system, based on automated criteria, makes it possible to identify the most vulnerable sectors and prioritize audits in high-risk organizations. In terms of results, in 2024, the Labour Inspectorate carried out approximately 19,000 control activities, detecting thousands of violations of labour regulations. As a result, more than 10,000 written orders were issued and sanctions were imposed on 8,281 officials.

Cuba recognizes the efforts made by Uzbekistan in implementing Conventions Nos 81 and 129 and its commitment to labour inspection as a fundamental pillar for ensuring decent work and social justice. We trust that this process will continue to move forward, with the support of the ILO and international cooperation.

Worker member, Germany – I speak on behalf of the German trade unions and wish to express our concern about the violations of Conventions Nos 81 and 129 by the Government of the Republic of Uzbekistan. In line with the Committee of Experts’ findings on Conventions Nos 81 and 129, we note that current labour inspection practices in Uzbekistan do not meet the required standards of scope, frequency or impartiality. We are deeply concerned about the 2018 moratorium placed on labour inspections, which represents a serious breach of the said Conventions. Unscheduled inspections are critical to prevent workplaces from concealing hazards before inspectors arrive. The ten-day advance notice requirement for inspections is a fundamental violation of the Conventions posing serious risks to workers’ health and safety.

Inspections focus on investigating and sanctioning infringements of labour standards and enterprises. Currently, a significant majority of inspections are conducted in response to complaints. Regular routine inspections must be intensified. Preventive inspections are crucial to prevent workplace accidents and tragedies before they happen.

To date, labour inspectors lack the authority to impose sanctions, to the detriment of their effectiveness.

Further, we emphasize that independent labour unions are essential for effective labour inspection and occupational safety. Therefore, it is impossible to address Conventions Nos 81 and 129 in isolation. The lack of truly independent labour unions is fundamental to commenting on the present case.

The FPU remains the sole workers’ federation in the country and serious concerns persist regarding its independence.

The union is State funded, and its leadership frequently includes individuals who hold Government positions. For example, the current head of the FPU is a senator. The first deputy is head of the Prime Minister’s Secretariat. As a result, the distinction between Government and trade unions remains blurred. In 2019, the adoption of the law on trade unions aimed to strengthen and clarify union rights. However, six years later, the law has failed to address concerns about union independence. Workers attempting to form independent unions remain unprotected and efforts to establish an independent union, as attempted in the cotton sector in 2021, were thwarted by State repression.

We noted that a German organization was approached to support the formation of a trade union in the country’s important textile sector. The German organization witnessed that the endeavour was driven by commercial actors and therefore declined the request to support the said trade union formation. German workers’ representatives remain firmly committed to the principles enshrined in the Freedom of Association and Protection of the Right to Organise Convention, 1948 (No. 87), and call upon the Uzbek Government to take meaningful steps towards implementation. We welcome the Government’s intention to increase the number of inspectors.

However, to ensure truly independent and effective labour inspections, Uzbekistan must fundamentally improve with regards to freedom of association, as occupational safety is indispensably linked to independent unions. Keeping the general situation of trade unions in mind, we call for immediate action by the Uzbek Government to immediately lift the 2018 moratorium on labour inspections, and to abolish the mandatory pre-registration of labour inspections. We call for a shift in the approach to labour inspections, placing greater emphasis on prevention. Also, we call for the authority to issue sanctions for labour inspectors and, lastly and most importantly, we call for the full implementation of Convention No. 87 in Uzbekistan.

Government member, Pakistan – Pakistan acknowledges the constructive efforts of the Republic of Uzbekistan to enhance its labour inspection system, in line with Conventions Nos 81 and 129. We have noted the substantial progress made in strengthening legal frameworks, improving institutional capacities and promoting compliance in both general and agricultural sectors. Uzbekistan’s continued engagement with the ILO supervisory mechanisms reflects its commitment to international labour standards. Pakistan supports a fair, balanced and forward-looking assessment of this case and encourages ongoing dialogue and cooperation to further consolidate these achievements.

Interpretation from Arabic: Government member, Oman – Oman would like to commend Uzbekistan for their efforts to bring themselves into compliance with international labour standards, particularly with regards to Conventions Nos 81 and 129. We also pay tribute to Uzbekistan’s cooperation with the Committee, in order to strengthen constructive dialogue with the ILO. As a result, we have seen that there has been technical assistance in order to enhance the implementation of these Conventions, thereby improving the drawing up of reports and statistics and ensuring the capacities of inspectors. We welcome these efforts and would like to reiterate how important our Committee is with regard to helping countries to comply with international labour standards, particularly with regard to allowing for sustainable development.

Government member, Switzerland – While commending the efforts by the Government, Switzerland remains concerned by the comments of the Committee of Experts regarding the situation concerning labour inspection in Uzbekistan. This situation is characterized by periods of suspension of labour inspections, as well as numerous restrictions on the exercise of the functions and powers of labour inspectors.

While noting the information provided by the Government, including the lifting of the moratorium on labour inspections, we encourage the Government to step up its efforts to ensure the proper functioning of the labour inspection system. We recall that it must be possible to carry out labour inspections without previous notice and as often and as thoroughly as necessary, and we therefore encourage the Government to lift the restrictions resulting from Presidential Decrees adopted several years ago which are still in force. These restrictions include:

• the requirement to give notice of inspections at least ten working days in advance;
• the requirement to obtain prior authorization, and the right of establishments to refuse an inspection if this procedure is not followed;
• the prohibition of carrying out repeat inspections;
• the impossibility for labour inspectors to question the employer or the staff, or to take or remove samples for purposes of analysis.

We note with interest the information indicating that efforts are under way to establish legal penalties for obstructing labour inspectors in the performance of their duties, and to ensure their effective enforcement in practice.

Finally, Switzerland encourages the Government to continue its cooperation with the ILO under the Decent Work Country Programme 2021–25, with a view to complying, in law and in practice, with its international obligations under Conventions Nos 81 and 129.

Interpretation from Chinese: Government member, China – We thank the President and the representative of the Government of Uzbekistan for the presentation. We have carefully reviewed the report of the Committee of Experts and the written materials submitted by the Government to the Committee. We note with appreciation that Uzbekistan attaches great importance to fulfilling its obligations under ILO Conventions, actively engages in cooperation with all parties, continues to advance reforms and promotes decent work and social justice.

The State Labour Inspectorate of Uzbekistan conducts regular and ad hoc inspections of employers in accordance with the law. The inspectors retain the authority to carry out unannounced inspections without prior approval and are unaffected by the Uzbek Government’s 2018 suspension of inspection measures. In response to comments from relevant parties, the Government of Uzbekistan provided detailed and targeted replies, including information on recent inspections and the handling of complaints. In 2024, Uzbekistan issued a Presidential Decree increasing the staffing of the State Labour Inspectorate by 16 per cent and at the beginning of this year, it conducted a comprehensive certification for all inspectorate personnel. The Government’s proactive and constructive approach deserves recognition by this Committee.

We welcome the ILO project on the improvement of labour inspection and occupational safety systems in Uzbekistan, which supports the analysis of existing national legislation at Uzbekistan’s request. We support the ILO in continuing to provide technical assistance to Uzbekistan to enhance the labour inspection capacity of relevant departments and to help the country to better fulfil its obligations under the Conventions.

Government member, Bolivarian Republic of Venezuela – The Bolivarian Republic of Venezuela thanks the Government for sharing a holistic view on the progress made and challenges faced in labour inspection and legislation in Uzbekistan. We appreciate the Government’s willingness to fulfil these responsibilities by promoting reforms that foster decent work, social justice and the protection of workers’ rights.

We note the recent measures implemented to strengthen labour inspection capacity, including the increase in personnel in the labour inspection services and continuous staff training. We also recognize that the digitalization of processes, the use of risk analysis, and the simplification of administrative procedures will be essential to improving the efficiency and transparency of inspection.

We emphasize the importance of social dialogue and cooperation with the various social actors, who, in addition to performing representative functions, actively participate in inspection activities, thereby complementing and strengthening the Government’s efforts in this regard.

To conclude, we urge the ILO to foster cooperation and technical assistance with the Government, with a view to further strengthening the country’s labour inspection and occupational safety systems. All of this in accordance with international Conventions, in support of a fairer, safer and more sustainable labour system.

Government member, Türkiye – Türkiye commends Uzbekistan’s ratification of all fundamental and governance Conventions and notes with appreciation the recent reforms, including the ratification of 11 ILO instruments within the last five years, which reflects a strong political commitment to labour rights and institutional development.

In light of Uzbekistan’s comprehensive reforms, Türkiye welcomes the Government’s clear political will to integrate Conventions Nos 81 and 129 into national practice. We note that the adoption of the new Labour Code in April 2023, coupled with the development of digital inspection systems and nationwide inspectors’ training supported by the ILO and Germany, reflects a holistic strategy, aimed at sustainable compliance and institutional capacity-building.

The full eradication of forced and child labour in agriculture, internationally recognized in 2022, demonstrates the tangible impact of these reforms. Uzbekistan’s model offers valuable lessons for rights-based governance and digital transformation in labour inspection systems across the region. We particularly welcome the recent removal of the requirement for business ombudsman approval for inspections, as well as the reintroduction of both planned and unannounced inspections in 2024, and the active enforcement efforts during the 2024 cotton harvest.

Türkiye notes with appreciation the progress made in institutional capacity-building, including the expansion of the State Labour Inspectorate staff, enhanced digital inspections such as the risk-based analysis system, and the increased transparency enabled by electronic sanctioning procedures.

We further highlight the strong record of performance in 2024, with nearly 50,000 violations identified, over 12,000 workers’ rights restored, and more than 8,000 officials held accountable.

At the same time, we encourage the Government of Uzbekistan to further align the powers of the State Labour Inspectorate with the full scope of Conventions Nos 81 and 129, including the ability to interrogate witnesses, collect samples, and act with independence and without undue procedural constraints.

We welcome the ongoing ILO technical cooperation project and support Uzbekistan’s request for continued assistance, particularly in the areas of legislative alignment, statistical capacity-building, and inspector training. Finally, we believe that Uzbekistan’s continuing reforms, coupled with open engagement with ILO’s supervisory system, will further advance the protection of workers and the realization of social justice.

Interpretation from Arabic: Government member, Saudi Arabia – Our delegation has taken note of the clarifications provided by Uzbekistan regarding developments in the national labour inspection system. We welcome the constructive cooperation with the ILO technical mechanisms and the comprehensive information provided, which demonstrate a clear commitment to dialogue and transparency. We welcome the progress made in strengthening institutional inspection capacities through regulatory reinforcement, capacity-building, etc. We also welcome Uzbekistan’s gradual approach based on progressive evaluation, a participatory approach and coordination with the social partners. We underline the importance of technical cooperation with the ILO. In conclusion, Saudi Arabia reiterates its full support for Uzbekistan’s efforts and encourages it to continue reforms to establish a balanced and effective inspection system to facilitate compliance and improve working conditions, taking into account national priorities and international commitments.

Observer, International Union of Food, Agricultural, Hotel, Restaurant, Catering, Tobacco and Allied Workers’ Associations (IUF) – Speaking on behalf of the IUF, we thank the Committee of Experts for the information provided and we thank the Government of the Republic of Uzbekistan for the detailed and honest report on the implementation of Convention No. 81.

Unfortunately, we cannot say that sufficient information is provided on Convention No. 129. Each Member of the ILO for which this Convention is in force, shall maintain a system of labour inspection in agriculture. The competent authority shall define the line which separates agriculture from industry and commerce, etc.

We regret to say that the figures given in the Government’s written and oral reports do not indicate in which sectors the inspections and the work of the Labour Inspectorate were carried out. It does not separate agriculture, and it is impossible to see from the report if and to what extent the agricultural sector specifically referred to in Convention No. 129 is covered by this work. We would like to recall that agriculture has one of the worst fatal accidents and occupational ill health records of any major employment sector.

Uzbekistan is one of the key suppliers of cotton to the international market and the issues of labour protection and respect for fundamental rights of workers in agriculture are of great importance here, especially for companies planning to invest in this industry after a long period of distrust and boycott of Uzbek cotton, which was caused by the systematic and massive use of forced labour of children in cotton farming. It was only three years ago, in March 2022, that the international boycott of Uzbek cotton was lifted. This was achieved through a remarkable effort of the Government to reform the industry and eliminate systematic child and forced labour.

Amid the general improvement, we still cannot ignore the regular reports from the country about problems with violations of human rights of agricultural workers and small farmers. This unfinished work keeps hindering the sustainability of the sector.

An example of this is a recent assessment by the European Bank for Reconstruction and Development of its funded project run by one of the agro-industrial companies in Uzbekistan, to which the Government allocated about 55,000 hectares for cotton cultivation in the Kashkadarya and Syrdarya regions. The cotton workers at these plantations made several attempts to unite, but all of them ended in the same way: the union was suppressed.

The Labour Inspectorate approached the situation concerning poor working conditions and safety standards in this area, but was not able to do anything, simply because workers were afraid to contact the labour inspectors and to openly and freely complain about the problems.

The situation perfectly illustrates the futility of efforts to strengthen inspections in the absence of freedom of expression, assembly and association.

The IUF submitted the complaint to the Committee of Freedom of Association, which is registered under No. 3487. We urge the Government of Uzbekistan to restore the right to freedom of association under Convention No. 87 and the Right to Organise and Collective Bargaining Convention, 1949 (No. 98).

Interpretation from Russian: Government representative – As speakers have pointed out, over the last two years the Uzbek Government has made quite a few changes to its legislation, including the adoption of the new Code I mentioned and the various other laws which have been put on the statute books. The moratorium that people have been talking about was withdrawn last year and so have certain other inappropriate procedures.

As I said, the system for carrying out inspections has now been improved. Having said that, the comments you have made, both positive and negative, and the suggestions you have put forward will all be taken into account by our authorities.

We understand your concern and we are quite happy to go back and check our legislation again and make changes and amendments where those are necessary, in order for us to be fully compliant with Conventions Nos 81 and 129.

We are coming to the final stages of the adoption of the separate document, which will improve the effectiveness and the solidity of our Labour Inspectorate and, as I said, in so far as possible, we will increase the number of inspectors, the quality of inspections and set appropriate levels for fines when they need to be levied. We also intend to improve the training and retraining provided to our inspectors.

We hope that, in taking into account the comments which have been made today and making the necessary amendments to our legislation and our procedures and practices, we will be able to improve the situation and bring ourselves fully into compliance with ILO standards.

Of course, we are open to constructive criticism and comments from the Committee of Experts and express our willingness to engage in dialogue with this Committee as and when necessary, and we hope that our needs will be taken into account and the assistance we need will be forthcoming in future technical cooperation with this Organization.

Employer members – The Employer members thank the various speakers who took the floor and, notably, the Government of the Republic of Uzbekistan for their intervention and information. The employers remind the Committee that Conventions Nos 81 and 129 are governance Conventions. The two Conventions ensure the effectiveness of the governance of the application of labour standards in practice.

As noted by the Employer members in our opening remarks, the Government of the Republic of Uzbekistan has been working with the ILO to improve labour inspections and occupational health and safety systems in the Republic of Uzbekistan. The Employer members acknowledge recent technical cooperation efforts between the Government and the ILO, including inspector training and study visits. However, these initiatives alone are insufficient to address the serious legislative and administrative barriers to effective labour inspections identified by the Committee of Experts.

The Employer members also acknowledge the request from the Government of the Republic of Uzbekistan first made on 8 May 2025 to the ILO Director-General for the ILO to provide technical assistance to ensure the full implementation of Conventions Nos 81 and 129.

On the basis of our earlier statements and, in light of the observations of the Committee of Experts, the Employer members recommend that the Government of the Republic of Uzbekistan do the following.

Number one, take the necessary measures to ensure that labour inspections are undertaken as often and as thoroughly as is necessary to ensure the effective application of legal provisions, including by ensuring that labour inspectors enter a workplace without prior notice. Labour inspectors carry out any examination, test or inquiry which they may consider necessary in order to satisfy themselves that the legal provisions are being strictly observed. This also includes interrogating alone or in the presence of witnesses the employer or their staff on any matters concerning the application of legal provisions, as well as labour inspectors notifying employers of their presence, unless they consider that such notification may be prejudicial to the performance of their duties.

Number two, for the Government to take necessary measures in order to ensure that effective and adequate enforcement and penalties are in place. This includes ensuring that labour inspectors have the power to exercise their discretion to give warning and advice, instead of instituting or recommending proceedings and establishing adequate penalties for obstructing labour inspectors in the performance of their duties.

Number three, provide the Committee of Experts with the various information requested.

Number four, be granted technical assistance as per the request from the Government of the Republic of Uzbekistan.

We trust that the Government of the Republic of Uzbekistan will provide their requested information by 1 September 2025 and adopt the measures indicated by this Committee in a timely manner.

Worker members – We thank the Government representative for the written and oral information he has provided. During our discussions, we noted that there are numerous violations of the Conventions in Uzbekistan. The recurring application of moratoriums on inspections is a source of deep concern. This is a serious violation of the Conventions. The Government should permanently lift all moratoriums on inspections in the country and ensure that such moratoriums are not reintroduced in the future.

We believe it is essential to strengthen the inspection services. We have noted the efforts of the Government to increase the number of labour inspectors and encourage it to intensify its efforts in this area. However, it will not be enough to simply increase the number of inspectors. It will also be necessary to ensure that they are trained and provided with all the necessary material and financial resources.

We have already reviewed the list of restrictions imposed on labour inspectors. Without revisiting this list, we nevertheless call on the Government to amend the relevant legislation in order to remove all the restrictions identified.

Hence the Government should take the necessary steps to ensure that labour inspectors:

• are authorized to carry out inspections without previous notice to any workplace liable to inspection;
• are authorized to carry out any examination, test or enquiry deemed necessary to satisfy themselves that the legal provisions are being observed;
• can choose not to notify the employer or their representative of their presence if they consider that such notification would prejudice the effectiveness of the inspection;
• can inspect establishments as often and as thoroughly as is necessary to ensure the effective application of the legal provisions.

A sufficient number of inspection visits without prior notice is necessary to enable inspectors to fulfil their obligation of confidentiality with regard to the source of any complaint, but also to avoid the establishment of any link between the inspection and a complaint. This is why we ask the Government to indicate the measures taken to ensure that inspectors treat the source of any complaint as strictly confidential and refrain from revealing to the employer or their representative that an inspection visit has been carried out further to a complaint.

The Government should also indicate the number of scheduled inspections carried out on the basis of the authorization of the Commissioner for the protection of the rights and legitimate interests of business entities, as well as the number of such inspections carried out further to a complaint.

The Government should also provide information on the number of requests for inspection submitted to the Commissioner and the number of cases in which such authorization was refused, indicating the reasons for the refusal. In its written information, the Government provides figures on the number of inspections carried out and the number of violations detected, but does not break down these figures as requested by the Committee of Experts.

The Government should also ensure that labour inspectors are free to decide whether to issue warnings or advice rather than institute or recommend proceedings. It should also provide information on the nature and number of violations detected during inspections, the number and nature of proceedings brought before the courts and the penalties subsequently imposed, including the amount of fines.

Finally, we request the Government to ensure that penalties are provided for in cases where labour inspectors are obstructed in the performance of their duties.

As the Government itself suggests, it will be important for it to continue to avail itself of ILO technical assistance to implement all the recommendations made. We ask the Government to do so by agreeing to an ILO direct contacts mission. We invite it to consider, in this context, the renewal of the “Improvement of Labour Inspection and Occupational Safety Systems in Uzbekistan” project, which was set up in collaboration with the ILO and will finish at the end of this year.

Conclusions of the Committee

The Committee took note of the oral and written information provided by the Government and the discussion that followed.

The Committee welcomed the Government’s use of ILO technical assistance to improve labour inspections. The Committee noted with concern the current practice of moratoriums on labour inspections in the country and the restrictions on the powers of labour inspectors.

Taking the discussion into account, the Committee urged the Government, in consultation with the social partners, and in line with the Conventions, to take effective and time bound measures to:

• eliminate the temporary ban on inspections and refrain from reintroducing such bans in the future;
• recruit labour inspectors and provide them with material, financial and operational resources in order to ensure the proper functioning of the Labour Inspectorate;
• ensure that labour inspections are undertaken as often and as thoroughly as necessary, including by ensuring that all the restrictions on the Labour Inspectors’ powers are removed;
• ensure that effective and adequate enforcement and penalties are in place, by ensuring that labour inspectors have the power to exercise their discretion to give warning and advice, instead of instituting or recommending proceedings, and establishing adequate penalties for obstructing labour inspectors in the performance of their duties.

The Committee invited the Government to continue availing itself of ILO technical assistance in this regard.

The Committee requested the Government to provide detailed and complete information to the Committee of Experts on measures taken in line with the Conventions by 1 September 2025.

Chairperson – I have the honour to give the floor to the distinguished representative of the Government of Uzbekistan, the Minister of Employment and Poverty Reduction.

Interpretation from Russian: Government representative – We would like to express our gratitude to the Committee of Experts and this Committee for the conclusions. The Government of the Republic of Uzbekistan would reaffirm its full commitment to implementing the ratified Conventions and its preparedness to continue working to ensure the effectiveness of labour inspection. We will look very closely at all of the recommendations, strengthen cooperation with the ILO and take the necessary measures to eliminate the problems that have arisen.

Direct Request (CEACR) - adopted 2025, published 114th ILC session (2026)

In order to provide a comprehensive view of the issues relating to the application of the ratified Conventions on labour inspection, the Committee considers it appropriate to examine Conventions Nos 81 (labour inspection) and 129 (labour inspection in agriculture) together.

Articles 3 and 5(a) of Convention No. 81 and Articles 6 and 12(1) of Convention No. 129. Functions of labour inspectors. Additional duties entrusted to labour inspectors. In its previous comments, the Committee requested the Government to provide information on the application of section 3 of Presidential Decision No. PP-3913; and section 38 of the Regulations on the State Labour Inspectorate of the Ministry of Employment and Labour Relations (Regulations on the SLI) contained in Annex 3 of the Decision of the Cabinet of Ministers No. 1066 of 31 December 2018. These provisions provide that the term of secondment of inspectorate personnel to investigation teams and inspections conducted by supervisory and law enforcement agencies shall be no more than ten days per month. The Committee observes that this is repeated in section 12(c) of the new Presidential Decree “On Measures to Improve State Policy and Enhance Effectiveness in the Sphere of Poverty Reduction and Employment” No. PD-347, of 4 October 2024 (Presidential Decree No. PD-347). The Committee also notes that section 12(b) of said Decree provides that, from 1 March 2025, the SLI and its branches are authorised to conduct inspections on whether the number of workers on public construction, repair or reconstruction projects matches project and contractor documentation funded from the State budget. The Committee once again requests the Government to indicate whether the ten-day limit established in these provisions refers to the time spent by inspectors on performing inspection visits for the enforcement of the legal provisions relating to conditions of work and the protection of workers while engaged in their work, as established in Article 3(1) of Convention No. 81 and Article 6(1) of Convention No. 129, or to other duties that might be entrusted to labour inspectors by other enforcement agencies, as referenced in Article 3(2) of Convention No. 81 and Article 6(3) of Convention No. 129. With regard to the new duties entrusted to labour inspectors under section 12(b) of Presidential Decree No. PD-347, the Committee requests the Government to indicate how it ensures that these functions do not interfere with the main objective of labour inspectors to ensure the protection of workers in accordance with labour inspectors’ primary duties as set forth in Article 3(1) of Convention No. 81 and Article 6(1) of Convention No. 129. In this respect, the Committee requests the Government to provide detailed information regarding the time and resources of the SLI that are allocated to these responsibilities in practice, as a proportion of inspectors’ overall time and resources.

Articles 4 and 5(b) of Convention No. 81 and Articles 7 and 13 of Convention No. 129. Supervision and control by a central authority. Collaboration between officials of the labour inspectorate and employers and workers or their organizations. With regard to its previous request on the inspection functions entrusted to trade unions by section 540 of the Labour Code and section 44 of the Trade Union law, the Committee notes the Government representative’s indication to the Conference Committee on the Application of Standards (Conference Committee) that these functions may include examining workplace safety at various stages of a project, participating in investigations into accidents, attending expert medical commissions and engaging in dispute resolution and legal actions on behalf of workers. The Government representative also indicated that trade unions do not have enforcement powers and conduct a type of “social control” which complements the work of the SLI. The Committee once again requests the Government to indicate the manner in which the central authority maintains supervision and control of the labour inspection system in its entirety and to specify the conditions and modalities under which the SLI collaborates with the labour inspection bodies under the authority of the trade unions. In its previous comments, the Committee noted that according to section 1 of Presidential Decree No. UP-5087 of 2017, the Chamber of Commerce and Industry is tasked with monitoring inspections of business entities and assessing the state of observance of the rights and legitimate interests of business entities, with findings submitted to the Presidential Administration, the Cabinet of Ministers and other relevant authorities. Noting the absence of information in this respect, the Committee once again requests the Government to provide information on the application of section 1 of Presidential Decree No. UP-5087/2017 and the assessment conducted by the Chamber of Commerce on labour inspection activities carried out by the SLI.

Articles 6 and 15(a) of Convention No. 81 and Articles 8 and 20(a) of Convention No. 129. Status and conditions of service of labour inspectors. Independence and impartiality of inspectors. With regard to the salaries and benefits of the inspectors in comparison with those of other public officials exercising similar functions in other Government services, the Committee notes the Government’s indication to the Conference Committee that labour inspectors are classified two grades above positions in the State Tax Committee and Ministry of Internal Affairs, making labour inspector salaries more competitive. The Government indicates in its report that the salaries of labour inspectors have been further increased and that, in order to ensure the independence of inspectors, their subordination to local authorities has been abolished. At the same time, the Committee notes that section 20 of Presidential Decree No. PD-347 grants the Minister of Poverty Reduction and Employment broad powers to appoint and dismiss heads of regional inspections, subject to agreement with regional and local authorities. The Committee requests the Government to provide further information on the mentioned salary increase. It also Committee requests the Government to indicate how it ensures that the appointment and dismissal of labour inspection staff are carried out in a manner that guarantees their independence from any external influence, in accordance with Article 6 of Convention No. 81. Furthermore, it requests the Government to continue to provide information on the measures taken or envisaged in order to ensure the impartiality, stability of employment and independence of labour inspectors in the performance of their duties, regardless of changes of government.

Article 7(3) of Convention No. 81 and Article 9(3) of Convention No.129. Training of labour inspectors. The Committee takes notes of the information provided by the Government in its report with regard to training offered to labour inspectors in 2025, including with technical support from the ILO. It also notes the indication that a mandatory system of professional development for SLI staff is being introduced, and that an Expert Council is being established under SLI which will be responsible for designing training programmes. The Government expresses the hope that following the introduction of the positions of State Agricultural Labour Inspector, ILO assistance will be provided in training those specialists. The Committee requests the Government to provide information on the measures taken to ensure that the envisaged mandatory systems for professional development for SLI staff, and the envisaged training programmes designed by the Expert Council will contribute to ensuring the completion of training for labour inspectors on the specific risks in agriculture upon their entry into service and in the course of employment.

Article 13 of Convention No. 81 and Articles 17 and 18 of Convention No. 129. Preventive and remedial actions adopted by labour inspectors. The Committee notes that section 8(4) of the Regulations on the SLI still limits the validity of an order to stop operations to a maximum period of ten days. The Committee notes the information provided by the Government with regard to written orders and representations issued by the SLI in the first semester of 2025. The Committee once again requests the Government to provide information on the application in practice of section 8(4) of the Regulations on the SLI, in particular with regard to the measures taken by labour inspectors in cases where the violations which justified a suspension order are not rectified within the ten days period. Noting that the Presidential Decree No PP-374 of 2022 has been amended, the Committee requests the Government to indicate whether, in case of violations identified during the implementation of preventive activities, labour inspectors are empowered to take measures, including suspension orders, with a view to remedying defects observed in plant layout or working methods which they may have reasonable cause to believe constitute a threat to the health or safety of the workers as required by Article 13(1) and (2) of Convention No. 81 and Article 18(1) and (2) of Convention No. 129. Noting the restrictions to the powers of labour inspections as examined in its observation under these Conventions, the Committee once again requests the Government to continue to provide information on the number of suspension orders and orders to remedy the violation of the law issued by labour inspectors, and the length of time that such orders were valid and in effect. Furthermore, the Committee once again requests the Government to provide information on the measures taken by the competent authority to determine the cases and conditions in which the labour inspection services in agriculture should be associated in the preventive control of new plant, materials or substances and new methods of handling or processing products which appear likely to constitute a threat to health or safety, in accordance with Article 17 of Convention No. 129.

Articles 14, 20 and 21 of Convention No. 81 and Articles 19(1), 26 and 27 of Convention No. 129. Annual report on the work of the inspection services. Notification of accidents and diseases. The Committee notes that the Government’s report and the 2024 Labour Inspection Report contain information regarding the staff of the labour inspection service (Article 21(b) of Convention No. 81 and Article 27(b) of Convention No. 129); statistics of inspection visits (Article 21(d) of Convention No. 81 and Article 27(d) of Convention No. 129); statistics of violations detected and penalties imposed (Article 21(e) of Convention No. 81 and Article 27(e) of Convention No. 129); and statistics of occupational accidents (Article 21(f) of Convention No. 81 and Article 27(f) of Convention No. 129). The Committee notes, however, that the reports do not contain statistics of workplaces liable to inspection and the number of workers employed therein (Article 21(c) of Convention No. 81 and Article 27(c) of Convention No. 129) and statistics of occupational diseases (Article 21(g) of Convention No. 81 and Article 27(g) of Convention No. 129). With regard to labour inspection in agriculture, the Committee notes that the 2024 Labour Inspection report provides detailed information on cotton monitoring, but does not include information on agriculture more broadly. In this respect, the Committee notes that the Government expresses hope for ILO assistance with regard to data collection system pertaining to agriculture. The Committee requests the Government to indicate the measures taken to ensure that its labour inspection reports are published and transmitted to the ILO, in accordance with Article 20 of Convention No. 81 and Article No. 26 of Convention No. 129, and that they contain information on all the subjects listed in Article 21 of Convention No. 81 and Article 27 of Convention No. 129. Noting that the Government once again did not provide information on cases of occupational diseases notified to the labour inspectorate, the Committee requests the Government to provide information on any measures taken or envisaged to improve the notification of cases of occupational diseases, in accordance with Articles 14 of Convention No. 81 and 19 of Convention No. 129.Noting the Government’s interest in receiving technical assistance in this regard, the Committee expresses the hope that, following such support, the Government will be able to provide disaggregated data for the agricultural sector in the future.

Observation (CEACR) - adopted 2025, published 114th ILC session (2026)

In order to provide a comprehensive view of the issues relating to the application of the ratified Conventions on labour inspection, the Committee considers it appropriate to examine Conventions Nos 81 (labour inspection) and 129 (labour inspection in agriculture) together.

The Committee notes the observations of the International Organisation of Employers (IOE), received on 1 September 2025, which reiterate the comments made in June 2025 by the employers’ group, as well as by the Employer member from Uzbekistan in the Conference Committee on the Application of Standards (Conference Committee) on the application of the Conventions by Uzbekistan. The Committee also notes the observations of the International Trade Union Confederation (ITUC) received on 2 September 2025. The Committee requests the Government to provide its comments in this respect.

Follow-up to the conclusions of the Committee on the Application of Standards (International Labour Conference, 113 th Session, June 2025)

The Committee notes the discussion which took place in the Conference Committee at the 113th Session (June 2025) of the Conference regarding the application of Conventions Nos 81 and 129 by Uzbekistan. In its conclusions, the Conference Committee noted with concern the practice of moratoria on labour inspections in the country and the restrictions on the powers of labour inspectors. The Conference Committee urged the Government, in consultation with the social partners, to take effective and time-bound measures to:

• eliminate the temporary ban on inspections and refrain from reintroducing such bans in the future;
• recruit labour inspectors and provide them with material, financial and operational resources in order to ensure the proper functioning of the Labour Inspectorate;
• ensure that labour inspections are undertaken as often and as thoroughly as necessary, including by ensuring that all the restrictions on the Labour Inspectors’ powers are removed;
• ensure that effective and adequate enforcement and penalties are in place, by ensuring that labour inspectors have the power to exercise their discretion to give warning and advice, instead of instituting or recommending proceedings, and establishing adequate penalties for obstructing labour inspectors in the performance of their duties.

The Conference Committee, welcoming the Government’s use of ILO technical assistance to improve labour inspections, invited the Government to continue availing itself of ILO technical assistance in this regard.

The Committee notes the Government’s report indicating that a series of measures have been taken following the conclusions of the Conference Committee, aimed at strengthening the labour inspection system and reaffirming its commitment to continue to avail itself of ILO technical assistance to ensure the effective implementation of the Conventions.

Articles 8, 10 and 11 of Convention No. 81 and Articles 10, 14 and 15 of Convention No. 129. Resources allocated to the Labour Inspectorate. The Government indicates in its report that, in July 2025, an order of the Minister of Employment and Poverty Reduction was approved, increasing the number of staff positions for state labour inspectors from 412 to 620, with recruitment for these new positions currently under way. The Committee notes with interest the introduction of the position of State Agricultural Labour Inspector at the territorial labour inspectorates. The Committee notes that the Government has not provided the number of employees currently working in the State Labour Inspectorate (SLI). Noting the ongoing recruitment, the Committee requests the Government to provide information on the number of labour inspectors, disaggregated by gender, currently employed by the SLI, at the central and regional levels, as well as the number of vacant positions. The Committee requests the Government to take the necessary measures to ensure the timely recruitment for the newly established labour inspection positions, including female inspectors, and to ensure that the SLI has sufficient material and financial resources, as well as the necessary transport facilities to effectively perform its duties.

Articles 12, 15(c) and 16 of Convention No. 81 and Articles 16, 20(c) and 21 of Convention No. 129. Powers of labour inspectors. Frequency and thoroughness of labour inspections.Moratorium on inspections. The Committee notes the Government representative’s indication to the Conference Committee that the entry into force of the new Labour Code in 2023 superseded previous decisions imposing a moratorium on labour inspections and that the moratorium was lifted in 2024. At the same time, the Committee notes that section 4 of Presidential Decree No. 5490 of 2018, which established a ban on inspection activities, is still in force. It also notes that, while Presidential Decree No. 126 of 4 August 2025 “On Additional Measures to Improve the System of Labour Relations and Vocational Training, as well as to Encourage Employers” (Presidential Decree No. 126), referred to by the Government, lifts some of the limitations on labour inspections, it does not lift the 2018 moratorium. Recalling once again that a moratorium placed on labour inspection is a serious violation of the Conventions, and with reference to its 2019 general observation on the labour inspection Conventions as well as to the conclusions of the Conference Committee, the Committee urges the Government to take the necessary measures to ensure legal clarity, including through amending section 4 of Presidential Decree No. 5490 of 2018 and refrain from reintroducing such bans in the future, in order to ensure that labour inspectors are able to undertake labour inspections as often and as thoroughly as is necessary to ensure the effective application of the legal provisions, in compliance with Article 16 of Convention No. 81 and Article 21 of Convention No. 129.

Other limitations. The Committee notes the Government’s indication that based on the recommendations of the Conference Committee, inspection activities have been fundamentally reformed and that the number of inspections of business entities has increased. In this respect, the Committee notes the lifting of certain restrictions previously identified by the Committee, including: (i) the requirement for the SLI to notify the business entity of the commencement of the inspection no later than 10 working days in advance (section 3(a) of the Presidential Decree No. 374 of 2022 as amended, and section 5(a)(ii) of Presidential Decree No. 126); (ii) the requirement that inspections are carried out only after preventive measures have been implemented (section 8 of the Appendix to Presidential Decree No. 374 of 2022, as amended); and (iii) the requirement for labour inspectors to seek prior approval for inspections from the authorized body for the protection of the rights and legitimate interests of business entities (Sections 9 and 14 of the Appendix to Presidential Decree No. 374).

At the same time, the Committee notes with deep concern that many of the restrictions on labour inspections imposed through Presidential Decree No. 5490 of 2018 and noted in the previous comment are still in force. In particular:

• section 5 still provides that: (i) all inspections of the activities of business entities conducted by supervisory authorities are subject to mandatory registration in the Unified System of Electronic Registration of Inspections; (ii) inspections carried out without registration in the Unified System of Electronic Registration of Inspections are illegal; and (iii) the coordination of inspections and control over the legality of their conduct are carried out by the authorized body for the protection of the rights and legitimate interests of business entities (“the authorized body”).
• section 8 still provides that the Ministry for the Development of Information Technologies and Communications, together with the Prosecutor General’s Office, shall develop the Unified System for Electronic Registration of Inspections which allows the authorized body to study the validity of the decisions taken by the supervisory authorities to conduct inspections and issue a permit; and to supervise the compliance of supervisory authorities with the procedure for conducting inspections established by law; while allowing business entities to receive, upon request, information about the inspection in the form of short messages (SMS) or via the internet in real time.
• although limitations on the duration of inspections set out in annexes 1 and 2 have been removed, section 4 still provides that inspections based on a complaint cannot last longer than one working day.

The Committee also notes that Presidential Decree No. 374 of 2022 maintains a number of restrictions to the powers of labour inspectors, providing that: (i) labour inspectors cannot conduct re-inspections (section 3(a)); (ii) business entities have the right to refuse inspections when the order to conduct an inspection was not drawn up in accordance with the established procedure or if the advance notification of the inspection was not carried out (section 3(b)); (iii) during the inspection, officials of the supervisory authority must neither go beyond the timeline, nor beyond the issues defined in the inspection programme (new section 21 of the Appendix to the Decree); (iv) before the start of the inspection, the inspector shall familiarize the head of the business entity with the purpose of the inspection, present them with an official ID giving the right to conduct the inspection, and provide copies of the documents that are the basis for the inspection (new section 15 of the Appendix to the Decree, which does not provide for any exemptions from such approach, as envisaged in Article 12(2) of Convention No. 81 and Article 16(3) of Convention No. 129); and (v) inspections can only be carried out during working hours (new section 22 of the Appendix to the Decree).

The Committee further notes once again that according to section 5 of Appendix 2 of the Decision of the Cabinet of Ministers No. 246 of 27 April 2017, concerning audits of occupational health and safety measures in workplaces to be carried out by legal entities on a contractual basis, no planned inspections should be carried out for three years in workplaces which are certified through such audits.

The Committee notes once again that the powers of inspectors, as set out in section 10 of the Regulations on the SLI, do not include the power to interrogate, alone or in the presence of witnesses, the employer or the staff of the undertaking on matters concerning the application of legal provisions (Article 12(1)(c)(i) of Convention No. 81 and Article 16(1)(c)(i) of Convention No. 129) or the power to take or remove, for purposes of analysis, samples of materials and substances used or handled (Article 12(1)(c)(iv) of Convention No. 81 and Article 16(1)(c)(iii) of Convention No. 129).

Lastly, the Committee notes the introduction of an exemption from inspections of low-risk business activities (as identified through a risk analysis procedure), as per section 5 of Presidential Decree No. 184 of 14 November 2024.

Noting that, while some limitations to labour inspection activities have been lifted, a series of restrictions still remain, the Committee requests the Government to take the necessary measures to ensure that labour inspectors: (i) are empowered to make visits to workplaces liable to inspection without previous notice, in conformity with Article 12(1)(a) of Convention No. 81 and Article 16(1)(a) of Convention No. 129; (ii) are empowered to carry out any examination, test or inquiry which they may consider necessary in order to satisfy themselves that the legal provisions are being strictly observed in conformity with Article 12(1)(c) of Convention No. 81 and Article 16(1)(c) of Convention No. 129; (iii) can choose not to notify the employer or their representative of their presence, if they consider that such notification may be prejudicial to the performance of their duties, in accordance with Article 12(2) of Convention No. 81 and Article 16(3) of Convention No. 129; and (iv) are able to undertake labour inspections as often and as thoroughly as is necessary to ensure the effective application of the legal provisions, in compliance with Article 16 of Convention No. 81 and Article 21 of Convention No. 129. In addition, the Committee requests that the Government take the necessary measures to ensure that risk assessment criteria do not limit the powers of labour inspectors or the undertaking of labour inspections.

The Committee also requests the Government to continue to provide information on inspections in practice, indicating the total number of workplaces liable to inspection, the number of scheduled and unscheduled inspections, and of on-site inspections and inspections without a visit to the workplace, as well as the number of inspections conducted in response to a complaint, and the results of all such inspections.

The Committee requests the Government to indicate the measures adopted in order to ensure that labour inspectors treat as absolutely confidential the source of any complaint and give no intimation to the employer that an inspection visit was made in consequence of the receipt of such a complaint.

The Committee requests the Government to continue to avail itself of the technical assistance of the Office, including by considering a review of the existing legislation in order to bring it in line with the Conventions.

Articles 17 and 18 of Convention No. 81 and Articles 22 and 24 of Convention No. 129. Prompt legal or administrative proceedings without previous warning and discretion of labour inspectors to give warning and advice. In its previous comments, the Committee had noted the Government’s indication in its report that inspectors are not empowered to impose administrative fines and that when administrative proceedings are brought against business entities, state labour inspectors submit the materials to the court in accordance with article 245(3) of the Administrative Liability Code. In this respect, the Committee notes the Government’s indication that the SLI is now authorized to examine cases of administrative offences provided for in the Administrative Code and impose fines for violations of labour legislation, including on occupational safety, and of legal requirements regarding the mandatory civil liability insurance of employers. The Committee notes that according to section 12 of Presidential Decree No. 347 of 4 October 2024, a procedure is established for applying fines to persons who violate the legislation on labour rights and labour protection, or interfere with, or influence the legal activities of officials of the SLI. The Government also indicates that a system has been introduced whereby inspectors impose fines electronically. In this respect, the Committee notes that under section 5(b) of Presidential Decree No. 126 a new system for considering and making administrative decisions on violations of labour legislation registered through the Unified Electronic Labour System will be introduced from 1 January 2026. The Committee requests the Government to provide more information on the procedure envisaged in section 12 of Presidential Decree No. 347. It also requests the Government to provide information on the application in practice of section 5 (b) of Presidential Decree No. 126 of 4 August 2025 once it is brought into effect.

Adequate penalties for violations of the legal provisions enforceable by labour inspectors. The Committee notes the Government’s indication that, by the end of 2025, revised fine levels for violations of occupational safety legislation will be approved. Regarding the need for adequate penalties for obstructing labour inspectors in the performance of their duties, the Committee notes the Government’s reply that in accordance with section 198 of the Code of Administrative Responsibility, individuals who fail to comply with lawful requirements of state labour inspectors or obstruct their official duties are subject to fines imposed for administrative liability. The Committee notes the information and data provided on penalties for the first half of 2025 as well as the information on violations in the 2024 Labour Inspection report. The Committee requests that the Government provide further information regarding the envisaged revised levels of fines, and concerning the application of adequate penalties for violations. It also requests the Government to provide updated information on the nature and number of violations detected in the course of inspections, any subsequent penalties applied, and the results of any cases referred to the courts.

The Committee is raising other matters in a request addressed directly to the Government.

Direct Request (CEACR) - adopted 2024, published 113rd ILC session (2025)

In order to provide a comprehensive view of the issues relating to the application of the ratified Conventions on labour inspection, the Committee considers it appropriate to examine Conventions Nos 81 (labour inspection) and 129 (labour inspection in agriculture) together.

Articles 3 and 5(a) of Convention No. 81 and Article 6 and 12(1) of Convention No. 129. Functions of labour inspectors. In its previous comment, the Committee requested the Government to provide information on the application of Section 2 of the Presidential Decision No. PP-3913/2018 on measures to improve the structure of labour bodies and strengthen the rules governing the protection of citizens’ employment rights and occupational safety (Presidential Decision No. PP-3913/2018) and section 38 of the Regulations on the State Labour Inspectorate of the Ministry of Employment and Labour Relations of the Republic of Uzbekistan (Regulations on the SLI), in Annex 3 of the Decision of the Cabinet of Ministers of the Republic of Uzbekistan No. 1066 of 31 December 2018. These provisions provide that the term of engagement (secondment) of inspectorate personnel to inspections (investigation teams) shall be no more than ten days per month. Noting the absence of information in this respect, the Committee requests once again the Government to clarify the meaning of these provisions and to provide information on their practical application. In particular, the Committee requests the Government to indicate whether the ten-day limit in these provisions refers to the time spent by inspectors in performing inspection visits for the enforcement of the legal provisions relating to conditions of work and the protection of workers while engaged in their work, as established in Article 3(1) of Convention No. 81 and Article 6(1) of Convention No. 129, or to other duties that might be entrusted to labour inspectors by other enforcement agencies, as referenced in Article 3(2) of Convention No. 81 and Article 6(3) of Convention No. 129.

Articles 4 and 5(b) of Convention No. 81 and Articles 7 and 13 of Convention No. 129. Supervision and control by a central authority. Collaboration between officials of the labour inspectorate and employers and workers or their organizations. The Committee notes that following the amendments to the Labour Code, section 535 of the Code provides that the State Labor Inspectorate (SLI) is a structural subdivision of the Ministry of Employment and Labor Relations of the Republic of Uzbekistan, which exercises state control and supervision over the compliance by employers with the requirements of labour legislation, legislation on employment of the population, on compulsory insurance of civil liability of the employer, on the rights of persons with disabilities, other legal acts on labour, labour protection rules and labour standards. In addition, section 540 of the Code provides that trade unions, their associations, divisions and primary trade union organizations have the right to exercise public control at workplaces over employers' compliance with the requirements of labour legislation and labour protection rules, as well as collective agreements, and other acts adopted by the employer in agreement with the trade union committee. In order to exercise this public control, trade unions, as well as their associations, have the right to create their own inspections. The Committee notes that: (i) section 44 of the Trade Union law still provides that trade union inspections may be established in the structure of trade unions, their associations and subdivisions, in which the relevant trade union inspectors carry out their activities; and (ii) according to section 10 of the Decree of the President of the Republic of Uzbekistan dated June 19, 2017 No. UP-5087 “On measures to radically improve the system of state protection of legitimate interests of business and further development of entrepreneurial activity”, the Chamber of Commerce and Industry of the Republic of Uzbekistan is tasked with monitoring the inspections of business entities and with conducting an analysis of the state of compliance by authorized bodies with the rights and legitimate interests of business entities. The result of this assessment is presented to the Administration of the President of the Republic of Uzbekistan and the Cabinet of Ministers of the Republic of Uzbekistan and other authorized bodies. Noting the absence of information in this regard, the Committee once again requests the Government to indicate the cases and conditions under which trade unions exercise the inspections functions entrusted to them by section 540 of the Labour Code and section 44 of the Trade Union law. The Committee requests the Government to indicate the manner in which the central authority maintains supervision and control of the labour inspection system in its entirety and to specify the conditions and modalities under which the SLI collaborates with the labour inspection bodies under the authority of the trade unions (including any delegation of powers and supervision of their activities). The Committee also requests the Government to provide detailed information on the functions exercised by the trade union labour inspectors in the areas of enforcement, prevention and provision of information and advice. It requests the Government to provide information on the number of trade union labour inspectors, their gender and geographical distribution, the nature of their professional training, and their fields of specialization. The Committee further requests the Government to provide information on the application of section 10 of the Decree of the President of the Republic of Uzbekistan dated June 19 2017 No. UP-5087 and on the assessment conducted by the Chamber of Commerce on labour inspection activities carried out by the SLI.

Articles 6, 11 and 15(a) of Convention No. 81 and Articles 8, 15 and 20(a) of Convention No. 129. Status and conditions of service of labour inspectors. Resources allocated to the labour inspectorate. Independence and impartiality of inspectors. The Committee notes that following the amendment of the Regulations on the SLI, section 39 of the Regulations provide that the monthly bonuses to be provided to the heads of labour bodies and employees of the inspectorate, in the amount of up to ten per cent of the fines levied on the administrative offences applied, should be no more than 35.15 times the minimum wage (previously the limit was set at 100 times the minimum wage). The Committee notes the Government’s indication, in its report, that at the territorial level, inspectors are provided with premises, at the district level inspectors have a separate room equipped with the necessary work facilities, and inspectors have their own workplace equipped with the necessary inventory and office equipment. The Government adds that transport facilities for the performance of duties are not provided, and reiterates that that the Regulations on the SLI provide for monthly payments to inspectors in the form of reimbursement for travel and meals expenses amounting to twice the minimum wage respectively. Noting the absence of a reply to its previous comment, the Committee requests once again the Government to provide specific information on the application in practice of section 39 of the Regulations on the SLI, including the amount of monthly bonuses awarded to individual inspectors in relation to the amount of the minimum wage. The Committee also requests once again the Government to provide information on: (a) the measures taken or envisaged in order to ensure the impartiality, stability of employment and independence of changes of government of labour inspectors in the performance of their duties; and (b) the salaries and benefits of the inspectors in comparison with those of other public officials exercising similar functions in other Government services, such as tax inspectors and police officers. The Committee further requests the Government to indicate the measures adopted in order to ensure that the SLI has sufficient material and financial resources to effectively perform its duties. In particular, noting that the 15 vehicles previously allocated to the SLI were withdrawn, the Committee requests the Government to provide information on how it ensures that labour inspectors are provided with transport facilities necessary for the performance of their duties in cases where suitable public facilities do not exist.

Article 7(3) of Convention No. 81 and Article 9(3) of Convention No.129.Training of labour inspectors. The Committee notes the adoption, in October 2022, of the new Regulations on the procedure for certifying officials of the supervisory bodies to grant the right to inspect the activities of business entities (Appendix 2 of the Resolution of the Cabinet of Ministers of the Republic of Uzbekistan, No. 611 dated 19.10.2022). The Committee notes that this Regulation provides: (i) for the certification of inspectors of business entities every three years; and (ii) that an official who is considered by the Attestation Commission to have not passed the attestation is prohibited from checking the activity of a business entity and may be re-certified after at least six months. With regard to training offered to labour inspectors, the Committee notes the Government’s indication that 15 inspectors completed an induction course in 2022 and 10 inspectors in the first nine months of 2023. In addition, 102 inspectors in 2022 and 17 inspectors in the first nine months of 2023 completed an advanced training. Noting the absence of information in this regard, theCommittee requests once again the Government to provide information on the training provided to labour inspectors on the specific risks in agriculture upon their entry into service and in the course of employment.

Articles 8 and 10 of Convention No. 81 and Articles 10 and 14 of Convention No. 129. Human resources of the labour inspectorate. The Committee notes the Government’s indication under Article 8 of Convention No. 81 and Article 10 of Convention No. 129 that as of January 2023, there were 278 inspectors, including 13 women (4.7 per cent of the total number of employees). However, the Committee further notes that under Article 10 of Convention No. 81 and Article 14 of Convention No. 129, the Government refers to a total of 309 labour inspectors, as of January 2023. The Committee requests the Government to clarify the number of labour inspectors, disaggregated by gender, employed by the SLI, and to provide information on the number of inspectors employed by the SLI at the central and regional levels. Noting that in 2021 the SLI had 348 inspectors, the Committee requests the Government to indicate the number of vacant positions, and the measures adopted in order to recruit new inspectors, including female inspectors.

Article 9 of Convention No. 81 and Article 11 of Convention No. 129. Duly qualified technical experts and specialists. The Committee notes the Government’s indication that according to the Resolution of the Cabinet of Ministers of the Republic of Uzbekistan No. 286 of 6 June 1997, on Investigating and Recording Industrial Accidents and Other Damage Caused to the Health of Workers in the Performance of their Duties, SLI officials shall have the right to invite experts to participate in the investigation of accidents, from whom an expert group may be established. In addition, the Government indicates that in accordance with the Regulations on the SLI, specialists with a higher technical education shall be hired for the position of state technical inspector for occupational safety. These include electrical power engineers, construction workers, agricultural engineers, mechanics, etc. The Government specifies that, SLI employs 202 inspectors with a higher legal education and 107 inspectors with a higher engineering and technical education. The Committee takes note of this information which addresses its previous request.

Article 13 of Convention No. 81 and Articles 17 and 18 of Convention No. 129. Preventive and remedial actions adopted by labour inspectors. The Committee notes that section 8(4) of the Regulations on the SLI, still limits the validity of an order to stop operations to a maximum period of ten days. The Committee further notes that section 54 of the Presidential Decree PP 374 of 13 September 2022, on measures to improve the procedure for coordinating inspections of business entities, provides that based on the deficiencies identified during the implementation of preventive measures, the official of the regulatory body shall assist the business entity in eliminating them, and also provide explanations or recommendations aiming at such rectification. The Committee notes the Government’s indication that in 2022, the labour inspectorate issued 9,331 orders to remedy identified violations, filed 2,675 submissions against officials who had violated labour legislation, and that in 134 cases it suspended activities of organizations or the operation of equipment that did not meet occupational safety requirements or posed a threat to the life or health of workers for a period of ten days. The Committee requests the Government to provide further information on the application in practice of section 8(4) of the Regulations of the SLI, in particular with regard to the measures taken by labour inspectors in cases where the violations which justified a suspension order are not rectified within the ten days period. The Committee further requests the Government to indicate whether, in case of violations identified during the implementation of preventive activities, labour inspectors are empowered to take measures with a view to remedying defects observed in plant, layout or working methods which they may have reasonable cause to believe constitute a threat to the health or safety of the workers, including suspension orders, as required by Article 13(1) and (2) of Convention No. 81 and Article 18(1) and (2) of Convention No. 129.Noting the restrictions to the powers of labour inspections as examined in its observation under these Conventions, the Committee requests the Government to continue to provide information on the number of suspension orders and orders to remedy the violation of the law issued by labour inspectors, and the length of time that each order was valid and in effect. Noting the absence of information on this matter, the Committee also requests the Government to provide information on the measures taken by the competent authority to determine the cases and conditions in which the labour inspection services in agriculture should be associated in the preventive control of new plant, materials or substances and new methods of handling or processing products which appear likely to constitute a threat to health or safety, in accordance with Article 17 of Convention No. 129.

Article 14 of Convention No. 81 and Article 19(1) of Convention No. 129. Notification of accidents and diseases. The Committee notes the Government’s indication in its report that in 2022, 878 special investigations of industrial accidents were conducted on the basis of accident reports submitted by employers. Noting the absence of information in this regard, the Committee requests once again the Government to provide information on the measures taken or envisaged in order to ensure that labour inspectors are notified of cases of occupational diseases, as required by Article 14 of Convention No. 81 and Article 19(1) of Convention No. 129. With reference to its comment below under Article 21 of Convention No. 81 and Article 27 of Convention No. 129, the Committee also requests the Government to include detailed information on the number of occupational accidents and diseases in the labour inspection report.

Articles 20 and 21 of Convention No. 81 and Articles 26 and 27 of Convention No. 129. Annual report on the work of the inspection services. The Committee notes the Government’s indication that the labour inspection reports for the years 2021 and 2022 have been prepared and published. The Government adds that the 2022 report contains information on laws and regulations relating to labour inspection activities; labour inspection personnel; statistics on inspection visits; statistics on violations identified and sanctions imposed; and statistics on industrial accidents. However, the Government indicates that statistics on the enterprises covered by inspection, and the number of workers employed therein, as well as statistics on occupational diseases have not yet been included. The Government also indicates that the 2022 report has been appended to its report. However, the Committee is bound to observe that such report has not been received by the Office. The Committee requests the Government to ensure that the labour inspection reports are published and transmitted to the ILO, in accordance with Articles 20 of Convention No. 81 and 26 of Convention No. 129. The Committee encourages the Government to pursue its efforts to ensure that future annual inspection reports contain complete information on all the subjects listed in Articles 21 of Convention No. 81 and 27 of Convention No. 129, including information on inspection activities in the agricultural sector.

Observation (CEACR) - adopted 2024, published 113rd ILC session (2025)

In order to provide a comprehensive view of the issues relating to the application of the ratified Conventions on labour inspection, the Committee considers it appropriate to examine Conventions Nos 81 (labour inspection) and 129 (labour inspection in agriculture) together.

Articles 12, 15(c) and 16 of Convention No. 81 and Articles 16, 20(c) and 21 of Convention No. 129. Powers of labour inspectors. 1. Moratorium on inspections. Following its previous comment, the Committee notes with deepconcern the Government’s statement that at present, no scheduled inspections are conducted in business entities due to a moratorium on inspections of the financial and economic activities of business entities, except for inspections conducted as part of criminal cases and in connection with the liquidation of a legal entity. The Government adds that, on the basis of applications from legal entities and individuals, the State Labour Inspectorate (SLI) has the right to initiate an inspection within the framework of the issues raised in the complaint. The Committee notes that the Presidential Decree No. UP-5490 of 15 March 2019 on Measures to improve radically the rules governing the protection of entrepreneurial activity and optimize the activities of the prosecutor’s office, which has established a ban on inspection activities starting from September 2018, is still in force. Recalling once again that a moratorium placed on labour inspection is a serious violation of the Conventions and with reference to its 2019 general observation on the labour inspection Conventions, the Committee urges the Government to eliminate the temporary ban on inspections and to ensure that labour inspectors are able to undertake labour inspections as often and as thoroughly as is necessary to ensure the effective application of the legal provisions, in compliance with Article 16 of Convention No. 81 and Article 21 of Convention No. 129.

2. Other limitations on labour inspections. The Committee notes with deepconcern that the restrictions on labour inspections, noted in the previous comment, established in the Presidential Decree No. UP-5490 of 15 March 2019, are still in force. In particular, section 5 of the Presidential Decree provides that: (i) all inspections of the activities of business entities conducted by regulatory authorities are subject to mandatory registration in the Unified System of Electronic Registration of Inspections; (ii) inspections carried out without registration in the Unified System of Electronic Registration of Inspections are illegal; and (iii) from 1 April 2019, the coordination of inspections and control over the legality of their conduct are carried out by the Commissioner under the President of the Republic of Uzbekistan for the protection of the rights and legitimate interests of business entities (hereinafter referred to as the authorized body). The Committee also notes that according to section 8 of the same Presidential Decree, the Ministry for the Development of Information Technologies and Communications, together with the Prosecutor General’s Office, shall develop the Unified System for Electronic Registration of Inspections which allows: (i) the authorized body to study the validity of the decisions taken by the regulatory authorities to conduct inspections and issue a permit with a unique code for their conduct; (ii) to supervise the compliance of regulatory authorities with the procedure for conducting inspections established by law; and (iii) business entities to receive, upon their request, information about the inspection in the form of short messages (SMS), as well as via the Internet in real time. The Committee notes that Annexes 1 and 2 of this Presidential Decree also set limitations on the duration of the inspections (one day for unscheduled inspections and between one and ten days for scheduled inspections). The Committee further notes that section 4 of the Presidential Decision No. PP-3913 of 20 August 2018, which provides that inspections based on a complaint cannot last longer than one working day and that during an inspection, inspectors may not interfere in the organization’s financial management activities, or any other of its activities that are unrelated to the object of the inspection, is still in force.

The Committee further notes the Government’s reference to the adoption of the Presidential Decree PP-374 of 13 September 2022, on measures to improve the procedure for coordinating inspections of business entities. The Committee notes with deepconcern that this decree contains a number of restrictions to the powers of labour inspectors, namely: (i) labour inspectors are obliged to provide a notification to the business entity of the commencement of the inspection no later than ten working days in advance and labour inspectors cannot conduct re-inspections (section 3(a)); (ii) business entities have the right to refuse inspections when the order to conduct an inspection was not drawn up in accordance with the established procedure or if the advance notification of the inspection was not carried out (section 3(b)); (iii) inspection activities are carried out only after preventive measures have been implemented (section 8 of the Appendix to the Decree); (iv) inspectors need to submit an application for approval of inspections to the authorized body (section 9 of the Appendix to the Decree); (v) the authorized body has the right to refuse inspections when: (a) the application for approval of the inspection has not been posted in the Information System; (b) in the event of initiation of an inspection in violation of the requirements of the legislation on appeals from individuals and legal entities; (c) if the facts that are the basis for initiating an inspection of a business entity are not confirmed; and (d) in case of violation of other requirements of legislation related to the activities of business entities (section 14 of the Appendix to the Decree); (vi) the order for inspections shall contain the purpose of the inspection, the term, and the period of activity subject to inspection (section 15 of the Appendix to the Decree); (vii) during the inspection, officials of the supervisory authority must not go beyond the timeline, the scope of their powers and the issues defined in the inspection programme (sections 23 and 25 of the Appendix to the Decree); (viii) before the start of the inspection, the inspector shall familiarize the head of the business entity with the purpose of the inspection, present him with an official ID giving the right to conduct the inspection, and provide copies of the documents that are the basis for the inspection (section 18 of the Appendix to the Decree); and (ix) inspections can only be carried out during working hours (section 25 of the Appendix to the Decree).

The Committee notes the Government’s indication in its report that in 2022, labour inspectors carried out 23,930 inspections and audits, of which 4,997 were conducted in accordance with the approved plan in state organizations, 47 with the permission of the Commissioner for Entrepreneurs’ Rights at business entities, 3,713 as specialists engaged by the investigative authorities, and 15,173 based on complaints from individuals.

The Committee further notes that according to section 5 of the Appendix 2 of the Decision of the Cabinet of Ministers of the Republic of Uzbekistan No. 246 of 27 April 2017, concerning audits of occupational health and safety measures in workplaces to be carried out by legal entities on a contractual basis, no planned inspections should be carried out for three years in workplaces which are certified through such audits.

Lastly, the Committee notes that section 10 of the Regulations on the SLI, which provides for the powers of the inspectors, does not include the power to interrogate, alone or in the presence of witnesses, the employer or the staff of the undertaking on matters concerning the application of the legal provisions (Article 12(1)(c)(i) of Convention No. 81 and Article 16(1)(c)(i) of Convention No. 129) or the power to take or remove, for purposes of analysis, samples of materials and substances used or handled (Article 12(1)(c)(iv) of Convention No. 81 and Article 16(1)(c)(iii) of Convention No. 129).

Noting the extent and the gravity of these restrictions, the Committee once again urges the Government to take the necessary measures to ensure that labour inspectors: (i) are empowered to make visits to workplaces liable to inspection without previous notice, in conformity with Article 12(1)(a) of Convention No. 81 and Article 16(1)(a) of Convention No. 129; (ii) are empowered to carry out any examination, test or inquiry which they may consider necessary in order to satisfy themselves that the legal provisions are being strictly observed in conformity with Article 12(1)(c) of Convention No. 81 and Article 16(1)(c) of Convention No. 129; (iii) can choose not to notify the employer or his representative of their presence, if they consider that such notification may be prejudicial to the performance of their duties, in accordance with Article 12(2) of Convention No. 81 and Article 16(3) of Convention No. 129; and (iv) are able to undertake labour inspections as often and as thoroughly as is necessary to ensure the effective application of the legal provisions, in compliance with Article 16 of Convention No. 81 and Article 21 of Convention No. 129.

The Committee recalls once again that, in the context of the implementation of the Decent Work Country Programme 2021–25, the Government can avail itself of the technical assistance of the ILO.

In addition, recalling once again that the performance of a sufficient number of unannounced inspection visits, as compared to inspections with prior notice, is necessary to enable labour inspectors to discharge their obligation of confidentiality with regard to the source of any complaint and also to prevent the establishment of any link between the inspection and a complaint (Article 15(c) of Convention No. 81 and Article 20(c) of Convention No. 129), the Committee requests the Government to indicate the measures adopted in order to ensure that labour inspectors treat as absolutely confidential the source of any complaint and give no intimation to the employer that an inspection visit was made in consequence of the receipt of such a complaint. The Committee requests the Government to indicate the number of scheduled inspections carried out based on the authorization of the competent authority and of those inspections conducted as a result of a complaint. The Committee also requests the Government to provide information on the number of requests for inspections submitted to the competent authority and the number of cases where such authorization was refused, and to indicate the reasons for the refusal.

Articles 17 and 18 of Convention No. 81 and Articles 22 and 24 of Convention No. 129. Effective enforcement and adequate penalties. The Committee notes the indication in the Government’s report that, in accordance with the Occupational Safety Act, and also the Regulations on the SLI, when violations of legislation are detected, the labour inspectors will first issue an order to address the violations identified and take preventive measures. The Government adds that, in the event of failure to comply with the order, in accordance with the Administrative Liability Code, inspectors shall consider cases of administrative offences under the articles 49, 49-1, 49-2, 49-3, 49-4, 50, 50-1, 51 and 51-1 of the Administrative Liability Code. The Government also indicates that inspectors are not empowered to impose administrative fines and that when administrative proceedings are brought against business entities, state labour inspectors submit the materials to the court in accordance with article 245(3) of the Administrative Liability Code. The Committee also notes the Government’s indication that in 2022, inspectors identified 89,586 violations of labour legislation, and issued 9,331 orders to remedy the violations identified, 10,622 enterprise officials were brought to administrative responsibility in the form of an administrative penalty, 1,098 items were handed over to law enforcement agencies, including 878 items resulting from special investigations of industrial accidents, and that in 9,535 cases of breaches of labour legislation identified, no penalties were imposed against enterprise officials as a result of prompt remedial actions. The Committee recalls that according to Article 17(2) of Convention No. 81 and Article 22(2) of Convention No. 129, it should be left to the discretion of labour inspectors to give warning and advice instead of instituting or recommending proceedings. Therefore, the Committee requests the Government to adopt the necessary measures in order to give effect to these provisions of the Conventions. The Committee further requests the Government to provide information on the nature and number of violations detected in the course of inspections, the number and nature of proceedings referred to the court and the subsequent sanctions imposed, including the amount of fines.

The Committee further notes the Government’s indication that section 538 of the Labour Code establishes liability for the obstruction of labour inspectors in the performance of their duties. However, the Committee notes that the legislation does not establish a sanction for such violation. In this regard, the Government indicates that work is under way to establish a measure of responsibility. The Committee requests the Government to indicate the measures adopted in order to introduce sanctions for cases of obstruction of labour inspectors in the performance of their duties.

The Committee is raising other matters in a request addressed directly to the Government.

Direct Request (CEACR) - adopted 2022, published 111st ILC session (2023)

In order to provide a comprehensive view of the issues relating to the application of the ratified Conventions on labour inspection, the Committee considers it appropriate to examine Conventions Nos 81 (labour inspection) and 129 (labour inspection in agriculture) together. The Committee notes the Government’s first reports on the application of these Conventions.

Legislative developments. The Committee notes that the Labour Code has been amended on 28 October 2022, and that the revised Labour Code will come into force in April 2023. The Committee will examine its conformity with these Conventions once the translation becomes available.

Articles 3 and 5 (a) of Convention No. 81 and Article 6 and 12(1) of Convention No. 129. Functions of labour inspectors. The Committee notes that according to the Government, the maximum time period for which monitoring and law enforcement authorities may call upon inspectors to perform inspections is set at ten working days per month, in accordance with the Presidential Decision No. PP-3913 of 20 August 2018 on measures to improve the structure of labour bodies and strengthen the rules governing the protection of citizens’ employment rights and occupational safety (Presidential Decision No. PP-3913/2018). The Committee also notes that according to section 38 of the Regulations on the State Labour Inspectorate of the Ministry of Employment and Labour Relations of the Republic of Uzbekistan (Regulations on the SLI), in Annex 3 of the Decision of the Cabinet of Ministers of the Republic of Uzbekistan No. 1066 of 31 December 2018, the term of engagement (secondment) of inspectorate personnel to inspections (investigation teams) shall be no more than ten days per month. The Committee requests the Government to clarify the meaning of these provisions and to provide information on their practical application. In particular, the Committee requests the Government to indicate whether the ten-day limit in these provisions refers to the time spent by inspectors in performing inspection visits for the enforcement of the legal provisions relating to conditions of work and the protection of workers while engaged in their work, as established in Article 3 (1) of Convention No. 81 and Article 6(1) of Convention No. 129, or to other duties that might be entrusted to labour inspectors by other enforcement agencies, as referenced in Article 3(2) of Convention No. 81 and Article 6(3) of Convention No. 129.

Articles 4 and 5(b) of Convention No. 81 and Articles 7 and 13 of Convention No. 129.Supervision and control by a central authority. Collaboration between officials of the labour inspectorate and employers and workers or their organizations. The Committee notes that according to section 9 of the labour code, the control and supervision of compliance with labour legislation and labour protection rules are carried out by specially authorized state bodies and their inspectorates and by trade unions. The Committee notes that the Presidential Decision No. PP-3913/2018, establishes the State Labour Inspectorate (SLI) under the Ministry of Employment and Labour Relations. The Committee also notes that according to section 44 of the Trade Union law, adopted in November 2019, in order to exercise public control over compliance with normative legal acts and normative documents in the field of technical regulation relating to the socio-economic rights and interests of workers, trade union inspections may be established in the structure of trade unions, their associations and subdivisions, in which the relevant trade union inspectors carry out their activities. The Committee requests the Government to indicate the cases and conditions under which trade unions exercise the inspections functions entrusted to them by section 9 of the Labour Code and section 44 of the Trade Union law.The Committee requests the Government to indicate the manner in which the central authority maintains supervision and control of the labour inspection system in its entirety and to specify the conditions and modalities under which the SLI collaborates with the labour inspection bodies under the authority of the trade unions (including the manner in which it delegates powers and supervises their activities). The Committee also requests the Government to provide detailed information on the functions exercised by the trade union labour inspectors in the areas of enforcement, prevention and provision of information and advice.It further requests the Government to provide information on the number of trade union labour inspectors, their gender and geographical distribution, the nature of their professional training, and their fields of specialization.

Articles 6, 11 and 15(a) of Convention No. 81 and Articles 8, 15 and 20(a) of Convention No. 129. Status and conditions of service of labour inspectors. Resources allocated to the labour inspectorate. Independence and impartiality of inspectors. The Committee notes the Government’s indication that labour inspectors hold the status of public official, as provided for in Presidential Decision No. PP-3913/2018. The Government also indicates that the tasks, functions, rights, obligations, incentives, and requirements for inspectors are defined in the Regulations on the SLI. The Government adds, however, that assurances of stability and independence of changes of government and of improper external influences are not provided in these Regulations. Concerning the material resources allocated to labour inspectors, the Committee notes the Government’s indication that according to the Regulations on the SLI, inspectors at the State Labour Inspectorate are provided with monthly payments, amounting to twice the minimum wage for the reimbursement of food expenses, and monthly payments, amounting to twice the minimum wage, for the reimbursement of travel expenses, except for inspectors who have access to inspectorate vehicles. The Government adds that inspectors in the regional offices are not offered reimbursements for travel or food expenses. The Government also indicates that, since September 2021, in order to streamline the expenses of budgetary organizations, the Ministry of Finance has proposed the withdrawal of the 15 passenger vehicles previously allocated to the inspectorate. In addition, the Committee notes that according to section 39 of the Regulations on the SLI, the heads of labour bodies and employees of the inspectorate are awarded monthly bonuses on the basis of an order of the Minister of Employment and Labour Relations, in the amount of up to ten per cent of the fines levied on the administrative offences applied, but not more than 100 times the minimum wage. The Committee recalls that, in conformity with Article 11 of Convention No. 81 and Article 14 of Convention No. 129, the necessary material resources should be allocated to labour inspectors so that they can carry out their duties effectively. The Committee is of the view that providing for the payment of incentive bonuses based on the amount of fines collected can affect the impartiality of labour inspectors in the performance of their duties and can create a situation of conflict of interest for labour inspectors, in violation of Articles 6 and 15(a) of Convention No. 81 and Articles 8 and 20(a) of Convention No. 129. Therefore, the Committee requests the Government to provide specific information on the application in practice of section 39 of the Regulations on the SLI, including the amount of monthly bonuses awarded to individual inspectors in relation to the amount of the minimum wage. The Committee also requests the Government to indicate the measures taken or envisaged in order to ensure the impartiality and independence of labour inspectors in the performance of their duties. The Committee also requests the Government to indicate how it ensures that labour inspectors are guaranteed stability of employment and independence of changes of government and of improper external influences. The Committee also requests the Government to provide specific information on the salaries and benefits of the inspectors in comparison with those of other public officials exercising similar functions in other Government services, such as tax inspectors and police officers. Moreover, it requests the Government to provide information on the budget and the material resources (such as vehicles, office equipment etc.) allocated to the labour inspectorate at the central and regional levels, and how it is ensured that labour inspectors at the regional level are reimbursed for any travel and incidental expenses which may be necessary for the performance of their duties.

Article 7 (3) of Convention No. 81 and Article 9 (3) of Convention No. 129.Training of labour inspectors. The Committee notes the Government’s indication that, once recruited, labour inspectors attend a two-week induction course and that afterwards they are expected to participate in national upskilling courses at least once every three years. A minimum of 36 hours of occupational safety training is compulsory for state technical inspectors, state working condition experts, and occupational safety specialists in trade union organizations. The Government also refers to the Resolution of the Cabinet of Ministers, dated 27 April 2017 No. 246, which contains Regulations on training and retraining in the field of occupational safety and health. With reference to its observation under Abolition of Forced Labour Convention, 1957 (No. 105), the Committee also notes that labour inspectors are receiving training by the ILO on forced labour investigations. The Committee also notes that the Regulations on the procedure for certifying officials of the supervisory bodies to grant the right to inspect the activities of business entities--approved by Decision of the Cabinet of Ministers No. 920 of 7 November 2018--which provided for the certification of labour inspectors at least once every three years, is no longer in force since October 2022. The Committee requests the Government to provide information on any measures adopted in order to regulate the certification of labour inspectors following the repeal of the relevant regulations on this matter. It also requests the Government to provide information on the training provided to labour inspectors on the specific risks in agriculture upon their entry into service and in the course of employment, noting the absence of information on this subject.

Articles 8 and 10 of Convention No. 81 and Articles 10 and 14 of Convention No. 129. Human resources of the labour inspectorate. The Committee notes that the Government provides detailed information on the number of labour inspectors assigned at the central and regional level. The Committee also notes that as of October 2021, there was a total of 303 labour inspectors (292 men and 11 women) employed in the SLI. According to the figures provided by the Government, this represents a decrease of 45 inspectors in comparison with the number reported as of January 2021, when the SLI counted 348 inspectors and 45 vacant posts. The Committee notes that the decrease of 45 inspectors includes some decline in 14 of the 15 listed offices, including an especially large decline (over 50 percent) in the Sirdaryo office. The Government indicates that a draft Presidential Decision is being prepared which will increase the number of inspectors and the degree of internal specialization. The Committee also notes that according to the 2020 Report on “Labour Rights Enforcement in Uzbekistan”, the SLI is resolved to increase the proportion of women inspectors and senior managers in future rounds of hiring. The Committee requests the Government to continue to provide information on the number of labour inspectors, disaggregated by gender, employed by the SLI at the central and regional levels. It also requests the Government to provide detailed information on the reasons for the decrease in the number of labour inspectors during 2021 in almost all offices, and on the plans for the recruitment of new inspectors, including female inspectors.

Article 9 of Convention No. 81 and Article 11 of Convention No. 129. Duly qualified technical experts and specialists. The Government indicates that labour inspection work is performed by duly qualified staff only. Certifications are conducted to assess a worker’s suitability for a particular role according to his or her professional profile and potential for career development and promotion. According to the Regulations on Investigating and Recording Industrial Accidents and Other Damage Caused to the Health of Workers Related to the Performance of their Duties, approved through Decision of the Cabinet of Ministers No. 286 of 6 June 1997, employers are obliged, at the instruction of the Committee for Special Investigations, to invite specialists and experts to participate in investigations into accidents. Specialists and experts may choose to form an expert group. The Committee requests the Government to provide additional details on the measures taken to give effect to Article 9 of Convention No. 81 and Article 11 of Convention No. 129, including information on the extent to which technical experts and specialists, including specialists in medicine, engineering, electricity and chemistry, are associated in the work of inspection.

Articles 12, 15(c) and 16 of Convention No. 81 and Articles 16, 20(c) and 21 of Convention No. 129. Powers of labour inspectors. 1. Moratorium on inspections. The Committee notes the Government’s indication that according to section 4 of Presidential Decree No. UP-5490 of 15 March 2019 on Measures to improve radically the rules governing the protection of entrepreneurial activity and optimize the activities of the prosecutor’s office, as of 1 September 2018, the following can no longer take place: (i) planned visits of inspection that are unrelated to an enterprise’s financial management activities; and (ii) inspections of an enterprise’s activities conducted as part of a monitoring procedure. The Committee notes that the preamble of this Presidential Decree indicates that large-scale reforms are being carried out in the country to ensure the unimpeded implementation of entrepreneurial activities and create favourable conditions for doing business and that therefore, all types of unscheduled inspections have been cancelled. Recalling with concern that a moratorium placed on labour inspection is a serious violation of the Conventions and with reference to its 2019 general observation on the labour inspection Conventions, the Committee urges the Government to eliminate the temporary ban on unscheduled inspections and to ensure that labour inspectors are able to undertake labour inspections as often and as thoroughly as is necessary to ensure the effective application of the legal provisions, in compliance with Article 16 of Convention No. 81 and Article 21 of Convention No. 129.

2. Other limitations on labour inspection. The Committee notes that according to section 5 of the Presidential Decree No. UP-5490 of 15 March 2019, from 1 September 2018: (i) an inspection of the activities of an enterprise may be initiated as a result of a risk assessment suggesting that an enterprise should undergo an inspection owing to the established likelihood that its activities may be in breach of legislation; (ii) all inspections of the activities of business entities conducted by regulatory authorities are subject to mandatory registration in the Unified System of Electronic Registration of Inspections; (iii) inspections carried out without registration in the Unified System of Electronic Registration of Inspections are illegal; and (iv) from 1 April 2019, the coordination of inspections and control over the legality of their conduct are carried out by the Commissioner under the President of the Republic of Uzbekistan for the protection of the rights and legitimate interests of business entities (hereinafter referred to as the authorized body). The Committee also notes that according to section 8 of the same Presidential Decree, the Ministry for the Development of Information Technologies and Communications, together with the Prosecutor General's Office, shall develop the Unified System for Electronic Registration of Inspections which allows: (i) the authorized body to study the validity of the decisions taken by the regulatory authorities to conduct inspections and issue a permit with a unique code for their conduct; (ii) to supervise the compliance of regulatory authorities with the procedure for conducting inspections established by law; (iii) the supervisory authorities to enter the results of the inspections carried out; and (iv) business entities to receive, upon their request, information about the inspection in the form of short messages (SMS), as well as via the Internet in real time. The Committee also notes the Government’s indication that, in accordance with section 4 of Presidential Decision No. PP-3913 of 20 August 2018, the SLI has the right, on the basis of a complaint submitted by a legal or natural person or a written notification from the state tax authorities, to conduct short and unplanned inspections on the compliance of an organization with legislative requirements on employment, labour, and occupational safety, without prior permission from the relevant authorized bodies and irrespective of the organization's legal form. This section also establishes that the duration of an inspection must not exceed one working day and that during an inspection, inspectors may not interfere in the organization’s financial management activities, or any other of its activities that are unrelated to the object of the inspection. The Committee further notes that according to section 11 of the Regulations on the SLI, in Annex 3 of the Decision of the Cabinet of Ministers of the Republic of Uzbekistan No. 1066 of 31 December 2018, inspectors shall be obliged to provide to the employer information and documents related to the subject of the inspection. The Committee further notes that section 10 of the Regulations on the SLI, which provides for the powers of the inspectors, does not include the power to interrogate, alone or in the presence of witnesses, the employer or the staff of the undertaking on matters concerning the application of the legal provisions (Article 12(1)(c)(i) of Convention No. 81 and Article 16(1)(c)(i) of Convention No. 129) or the power to take or remove, for purposes of analysis, samples of materials and substances used or handled (Article 12(1)(c)(iv) of Convention No. 81 and Article 16(1)(c)(iii) of Convention No. 129). The Committee notes that, according to the 2020 Report on “Labour Rights Enforcement in Uzbekistan”, the number of companies inspected increased from 5,638 in 2018 to 19,226 in 2020. The Committee notes with concern the statement of the Government in its report that SLI officials are unable to: (i) enter freely and without previous notice at any hour of the day or night any workplace liable to inspection; (ii) to enter by day any premises which they may have reasonable cause to believe to be liable to inspection; or (iii) to carry out any examination, test or inquiry which they may consider necessary in order to satisfy themselves that the legal provisions are being strictly observed.

In light of the above the Committee urges the Government to take the necessary measures to ensure that labour inspectors: (i) are empowered to make visits to workplaces liable to inspection without previous notice, in conformity with Article 12(1)(a) of Convention No. 81 and Article 16(1)(a) of Convention No. 129; (ii) are empowered to carry out any examination, test or inquiry which they may consider necessary in order to satisfy themselves that the legal provisions are being strictly observed in conformity with Article 12(1)(c) of Convention No. 81 and Article 16(1)(c) of Convention No. 129; and (iii) can choose not to notify the employer or his representative of their presence, if they consider that such notification may be prejudicial to the performance of their duties, in accordance with Article 12(2) of Convention No. 81 and Article 16(3) of Convention No. 129.

The Committee recalls that, in the context of the implementation of the Decent Work Country Programme 2021-25, the Government can avail itself of the technical assistance of the ILO.

In addition, recalling that the performance of a sufficient number of unannounced inspection visits, as compared to inspections with prior notice, is necessary to enable labour inspectors to discharge their obligation of confidentiality with regard to the source of any complaint and also to prevent the establishment of any link between the inspection and a complaint (Article 15(c) of Convention No. 81 and Article 20(c) of Convention No. 129), the Committee requests the Government to indicate the measures adopted in order to ensure that labour inspectors treat as absolutely confidential the source of any complaint and give no intimation to the employer that an inspection visit was made in consequence of the receipt of such a complaint. The Committee requests the Government to indicate the number of scheduled inspections carried out based on the authorization of the Commissioner for the protection of the rights and legitimate interests of business entities and of those inspections conducted as a result of a complaint. The Committee also requests the Government to provide information on the number of requests for inspections submitted to the Commissioner and the number of cases where such authorization was refused, and to indicate the reasons for the refusal.

Article 13 of Convention No. 81 and Articles 17 and 18 of Convention No. 129. Preventive and remedial actions adopted by labour inspectors. The Committee notes the Government’s reference to the powers of labour inspectors, prescribed in section 28 of the Act on Occupational Safety and Health No. ZRU-410 (Act on OSH), to issue an order to the head of an organization, or other official thereof, to redress violations of legislation on occupational safety and to suspend the activities of organizations or the operation of equipment that do not meet the requirements of labour safety and pose a threat to the life or health of employees. The Government also refers to the provisions of the Regulations on the procedure for suspending the activities of organizations for breaches of occupational safety legislation, approved by Decision of the Cabinet of Ministers No. 1 of 5 January 2011. The Committee notes that according to section 5 of these Regulations, labour inspectors have the power to issue written orders to eliminate violations of the law, which are subject to mandatory execution. The Committee also notes that sections 8(4) of the Regulations on the SLI, appears to limit the validity of an order to stop operations to a maximum period of ten days. The Committee further notes that the 2020 Report on “Labour Rights Enforcement in Uzbekistan” does not contain information on the number and nature of preventive and remedial actions adopted by labour inspectors. The Committee requests the Government to provide information on the application in practice of section 8(4) of the Regulations of the SLI. Noting the restrictions to the powers of labour inspections as examined in its observation under these Conventions, the Committee requests the Government to provide information on the number of suspension orders and orders to remedy the violation of the law issued by labour inspectors, and the length of time that each order was valid and in effect. Noting the absence of information on this matter, the Committee also requests the Government to provide information on the measures taken by the competent authority to determine the cases and conditions in which the labour inspection services in agriculture should be associated in the preventive control of new plant, materials or substances and new methods of handling or processing products which appear likely to constitute a threat to health or safety, in accordance with Article 17 of Convention No. 129.

Article 14 of Convention No. 81 and Article 19(1) of Convention No. 129. Notification of accidents and diseases. The Government indicates that, according to the Regulations on investigating and keeping records of industrial accidents and other harm caused to the health of workers in connection with the performance of their duties, approved by Decision of the Cabinet of Ministers No. 286 of 6 June 1997, employers must immediately report any accident that is fatal, causes serious injury, or involves more than one person. It adds that the reporting of cases of occupational diseases to the SLI is not provided for under national legislation and that information on occupational diseases can be provided by the Ministry of Health at the request of the SLI. The Committee requests the Government to provide information on the measures taken or envisaged in order to ensure that labour inspectors are notified of cases of occupational diseases, as required by Article 14 of Convention No. 81 and Article 19(1) of Convention No. 129. It also requests the Government to include detailed information on the number of occupational accidents and diseases in the labour inspection report, as provided in Article 21 of Convention No. 81 and Article 27 of Convention No. 129.

Articles 17 and 18 of Convention No. 81 and Articles 22 and 24 of Convention No. 129. Effective enforcement and adequate penalties. The Committee notes the Government’s indication that, according to section 255 of the Administrative Liability Code, labour inspectors have the right to consider administrative offences and impose administrative penalties. The Committee also notes that according to section 10 of the Regulations on the SLI, in order to perform the tasks and functions assigned to them, labour inspectors shall have the right to (i) carry out proceedings in cases of administrative offences, to consider cases within their competence and to apply administrative penalties; and (ii) prepare and send to law enforcement agencies and the courts, documents for bringing offenders to justice, including for criminal liability, in accordance with national legislation. The Committee notes that the Labour Code, the Administrative Liability Code and the Act on OSH provide for penalties for violations of provisions pertaining to conditions of work and occupational safety and health. The Committee further notes that the 2020 Report on “Labour Rights Enforcement in Uzbekistan” contains information concerning the total number of written submissions, fines imposed and prosecutions and the number and amount of fines issued specifically for cases of forced labour. The Committee requests the Government to provide further information on the application of adequate penalties for violations of the legal provisions enforceable by labour inspectors. It also requests the Government to provide information on the nature and number of violations detected in the course of inspections, any subsequent penalties applied, and the results of any cases referred to the courts.

Articles 20 and 21 of Convention No. 81 and Articles 26 and 27 of Convention No. 129. Annual report on the work of the inspection services. The Committee notes the publication in 2020 of the Report on “Labour Rights Enforcement in Uzbekistan” which contains information on the activities of labour inspectors such as the number of inspection visits, statistics of penalties imposed, number and type of complaints received, amount of fines imposed for violation of provisions on forced labour, and number of industrial accidents. The Committee further notes that the Government report contains information on the number of labour inspectors and on the number of establishments, disaggregated between agricultural and other establishments. The Committee also notes the Government’s indication that a report on the activities of the inspectorate in agriculture has not been published. The Committee requests the Government to ensure that the labour inspection reports are published and transmitted to the ILO, in accordance with Articles 20 of Convention No. 81 and 26 of Convention No. 129. The Committee encourages the Government to pursue its efforts to ensure that future annual inspection reports contain complete information on all the subjects listed in Articles 21 of Convention No. 81 and 27 of Convention No. 129, including information on inspection activities in the agricultural sector.