Following the adoption of Presidential Resolution No. PP-294 dated 14 August 2026, “On Measures to Improve the Provision of Instalment Payment Services to the Population,” claims began circulating that from 1 January 2027 it would no longer be possible to purchase an apartment in Uzbekistan by instalments. This is an incorrect interpretation of the Resolution. PP-294 does indeed provide that real estate may not be the subject of an instalment payment service, but this restriction concerns a specific new financial model — a service provided by an instalment payment operator. Where the seller and buyer deal directly with each other, a different legal regime applies. If the apartment is still under construction, a third set of rules must also be taken into account — the special legislation governing shared-equity construction and escrow accounts. Accordingly, the answer to the question “Can an apartment be purchased by instalments?” depends primarily on who is selling the property, whether the property has already been completed, and what type of agreement is used to structure payment in instalments. PP-294 entered into force on 17 August 2026. However, the activities of instalment payment service operators must be organised from 1 January 2027. Subparagraph “a” of paragraph 3 provides a special definition of an instalment payment service. It refers to a situation where a legal entity pays the seller the cost of goods, works, or services on behalf of an individual, after which the consumer reimburses that legal entity for the amount paid together with a commission or markup. In other words, a separate intermediary enters the transaction and finances the purchase. At the same time, PP-294 contains a crucial qualification: cases where the seller sells directly to the consumer are expressly excluded from the concept of such a service. This distinction is particularly important in relation to real estate. Subparagraph “d” of paragraph 3 of PP-294 provides that: real estate, as well as other property withdrawn from circulation or restricted in circulation, may not be the subject of instalment payment services. Accordingly, from 1 January 2027, a specialised instalment payment operator will not be permitted to structure a transaction whereby it pays the seller for an apartment on behalf of an individual and the individual subsequently repays the purchase price to the operator together with a commission or markup. However, this does not amount to a prohibition on all forms of payment for real estate in instalments. PP-294 regulates a service provided by an intermediary operator and, at the same time, expressly excludes direct sales by a seller to a consumer from the definition of such a service. For a completed property, such a possibility exists under civil legislation, although the transaction must be properly characterised. Article 421 of the Civil Code regulates the sale of goods on credit — that is, a situation where payment is made after the goods have been transferred. Article 422 expressly permits payment by instalments. A contract is deemed concluded where, in addition to the other essential terms, it specifies the price of the goods, the payment procedure, the payment schedule, and the amount of each payment. The rules governing the sale of real estate are contained in Articles 479–488 of the Civil Code. The transfer of title to real estate to the purchaser is subject to state registration, while a contract for the sale of a residential house, apartment, or a part thereof must be notarised and registered with the state. Thus, the Civil Code recognises the legal structure of a sale with deferred or instalment payment and does not contain a general prohibition, within the section regulating real estate sales, on payment of the purchase price in this manner. There is another important provision that cannot be ignored. Article 53 of Law No. ZRU-803 dated 28 November 2022, “On State Registration of Rights to Real Estate,” expressly refers to a contract for the sale and purchase of real estate on deferred-payment terms. Where the transfer of property rights under such a transaction is connected with a mortgage, the related rights and encumbrances must be registered simultaneously. Accordingly, the legislation on state registration expressly proceeds from the existence of real estate sale transactions in which payment is not made in a single lump sum. Article 6 of the same Law establishes the mandatory state registration of the creation, transfer, restriction, and termination of rights to real estate. This is where another important rule is found, meaning that PP-294 cannot be analysed in isolation. Article 5 of Law No. ZRU-33 dated 6 May 2006, “On Consumer Credit,” defines commodity consumer credit as credit provided to a consumer in the form of instalment payment for purchased goods, completed works, or rendered services. Article 6 of the same Law expressly provides that: real estate may not be the subject of consumer credit. At first sight, this may appear contradictory: the Civil Code permits instalment sales, Law No. ZRU-803 expressly refers to real estate sold on deferred-payment terms, while the Law “On Consumer Credit” prohibits real estate from being the subject of consumer credit. However, these provisions regulate legal structures that are not identical. The legal classification of the agreement is therefore decisive. One situation is a contract for the sale and purchase of real estate under which the parties agree that the purchase price will be paid in instalments. A different situation is the provision of consumer credit to an individual as an independent financial product. Article 7 of Law No. ZRU-33 further characterises consumer credit as being provided on the basis of payment, maturity, and security. Therefore, a direct sale of completed real estate with deferred or instalment payment of the purchase price should not automatically be structured or described as “commodity consumer credit,” because Article 6 expressly prohibits real estate as the subject of such credit. This distinction has become particularly significant following the adoption of PP-294. Where real estate is transferred before full payment has been made, the seller must determine in advance how the outstanding balance will be secured. Article 421 of the Civil Code provides that, from the moment the goods are transferred to the buyer until full payment is made, goods sold on credit are deemed to be pledged to the seller as security for the buyer’s payment obligation. In addition, Law No. ZRU-58 dated 4 October 2006, “On Mortgage,” expressly permits a mortgage to secure an obligation arising, among other things, from a sale and purchase agreement. An apartment or other registered real estate may be the subject of a mortgage. Article 53 of Law No. ZRU-803 also requires simultaneous state registration of interconnected rights and restrictions, including those arising from the sale of real estate on deferred-payment terms and from a mortgage. Accordingly, a transaction structured as “title transfers immediately to the buyer, while payment is made over several years” should not be treated merely as a payment schedule. The parties must also determine how the unpaid portion of the purchase price will be secured and how that security will be registered with the state. Purchasing a completed and registered apartment and financing the construction of a future apartment are legally different situations. Presidential Decree No. UP-11 dated 27 January 2025 introduced a special regime for attracting funds from participants in shared-equity construction. From 1 July 2025, funds from participants may be attracted for construction only on the basis of a notarised shared-equity participation agreement that has undergone state registration with the cadastral authorities. Funds under such an agreement must be placed and deposited in an escrow account with an authorised commercial bank. From 1 January 2026, funds from participants for construction may be attracted only through escrow accounts. This requirement is already in force. Therefore, merely describing an agreement as “developer instalments” does not remove the relationship from the scope of UP-11. If, in economic and legal substance, the developer is receiving money from an individual to finance a property that is still under construction, compliance with the shared-equity construction regime must be verified. Moreover, subparagraph “k” of paragraph 2 of UP-11 expressly prohibits the conclusion of other types of agreements that do not comply with the procedure established by the Decree for attracting funds from participants for construction of a property for which a permit for use has not yet been issued. This is one of the most important rules for purchasers of new-build apartments. The first situation is where the apartment has already been completed, title to it has been registered, and the owner directly sells it to the buyer with the purchase price payable in instalments. PP-294 excludes such a direct sale from the concept of an instalment payment operator service. The transaction is governed by the Civil Code provisions on credit sales and instalment payments, the special provisions governing the sale of real estate, and the requirements of notarisation and state registration. The second situation is where the apartment is effectively financed by a third-party organisation: that organisation pays the seller, while the buyer subsequently repays the debt to that organisation together with a markup. This is the instalment payment operator model regulated by PP-294. From 1 January 2027, real estate may not be the subject of such a service. The third situation is where the apartment does not yet exist as a completed independent property and the individual’s funds are transferred to the developer during construction. In this situation, UP-11 applies: a shared-equity participation agreement, notarisation and state registration of that agreement, use of the electronic platform, and, from 1 January 2026, an escrow account are required. The title of the agreement does not change its legal nature. For those goods, works, and services that may be acquired through instalment payment operators, separate restrictions will apply. The value of the subject of such a service may not exceed 250 BCV. The commission, markup, and other payments must be stated separately. The consumer will have the right at any time to repay the outstanding amount, in whole or in part, ahead of schedule without any additional fine, penalty, or commission. The maximum term of an obligation under an operator instalment payment agreement is 12 months. If an agreement provides for instalment payments for more than 12 months, PP-294 classifies it as a consumer credit agreement. Operators will also be entered into a special register maintained by the Central Bank. This is also important for any publication on this subject. Paragraph 7 of PP-294 instructs the Central Bank, together with other government authorities, to prepare within three months amendments and additions to legislation arising from the Resolution. In addition, a separate draft law regulating the activities of instalment payment service operators must be submitted by 1 January 2027. Accordingly, as of 29 August 2026, the new legal regime remains in the process of further regulatory development. For this reason, any statement that “instalment payments for housing will be completely prohibited from 2027,” or, conversely, that “nothing at all will change for developers,” is an excessive simplification. PP-294 does not establish a general prohibition on the sale of real estate with payment in instalments. It prohibits real estate from being the subject of the special instalment payment service provided by an intermediary operator. Direct sales by a seller to a consumer are expressly excluded from the definition of such a service. Where existing real estate is sold, the provisions of the Civil Code on credit sales and instalment payments, the special rules governing real estate sales, Law No. ZRU-803 on state registration, and, where necessary, mortgage legislation must be applied. At the same time, the agreement should not mistakenly be structured as commodity consumer credit: Article 6 of the Law “On Consumer Credit” expressly excludes real estate from the objects of such credit. Where an individual pays for an apartment that is still under construction and the individual’s funds are attracted for construction purposes, the special regime established by UP-11 applies: from 1 January 2026, such funds may be attracted only through escrow accounts. Therefore, the key issue in 2026–2027 is not the word “instalment” itself, but the legal structure of the transaction. Prepared as of 29 August 2026.Instalment Payments for Real Estate from 2027: What Presidential Resolution No. PP-294 Actually Prohibits
What Exactly Does PP-294 Regulate?
Where Exactly Is the Prohibition on Real Estate Established?
Does This Mean That a Developer Can Simply Sell an Apartment by Instalments?
This Is Also Confirmed by the Law on State Registration of Real Estate
But There Is Also the Law “On Consumer Credit”
How Can the Unpaid Portion of the Purchase Price Be Secured?
A Completely Different Regime Applies if the Apartment Is Still Under Construction
Therefore, “Developer Instalments” May Refer to Three Completely Different Transactions
What Other Requirements Will PP-294 Introduce from 2027?
The Regulatory Framework for 2027 Has Not Yet Been Finalised
Conclusion
Legal Framework
