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Legal Regulation of Electronic Contracts in Uzbekistan and China: A Comparative Legal Study

Authors

  • LIU XIANG

    BUKHARA STATE UNIVERSITYб Republic of Uzbekistan
    Author

Keywords:

electronic contracts; electronic commerce; electronic signature; data messages; Uzbekistan; China; comparative law; civil law; platform governance

Abstract

This article examines the legal regulation of electronic contracts in the Republic of Uzbekistan and the People's Republic of China through a comparative doctrinal method. Electronic contracts are no longer an exceptional technique for online sales; they are a normal form of civil turnover, consumer transactions, platform commerce, digital services, and cross-border trade. The central research question is how two civil-law jurisdictions connect general contract doctrine with special rules on electronic commerce, data messages, electronic signatures, platform duties, evidence, and consumer protection. Uzbekistan has adopted a dedicated Law on Electronic Commerce and a renewed Law on the Electronic Digital Signature in 2022, while China integrates electronic contracting into the Civil Code, the Electronic Signature Law, and the E-Commerce Law. The comparison shows substantial convergence in recognizing electronic form, offer and acceptance, legal equivalence, and evidentiary value, but also important differences in legislative technique, platform governance, judicial guidance, and the treatment of automated and standard-form transactions. The article concludes that Uzbekistan's recent reforms provide a strong framework, but further clarification of platform responsibility, standard terms, automated contracting, cross-border recognition of signatures, and electronic evidence would increase transactional certainty.

References

1. Civil Code of the Republic of Uzbekistan, especially provisions on transactions, written form, offer and acceptance, contract conclusion, performance, and liability.

2. Law of the Republic of Uzbekistan 'On Electronic Commerce', No. LRU-792, 29 September 2022, Lex.uz, https://lex.uz/en/docs/6907193.

3. Law of the Republic of Uzbekistan 'On the Electronic Digital Signature', No. LRU-793, 12 October 2022, Lex.uz, https://lex.uz/en/docs/6907238.

4. Civil Code of the People's Republic of China, adopted 28 May 2020, effective 1 January 2021, especially Articles amended. 469

and 491. Official English archive: https://english.www.gov.cn/archive/lawsregulations/202012/31/content_WS5fedad98c6d 0f72576943005.html.

5. Electronic Signature Law of the People's Republic of China, adopted 2004 and subsequently National Database of Laws and Regulations: https://flk.npc.gov.cn/.

6. E-Commerce Law of the People's Republic of China, adopted 31 August 2018 and effective 1 January 2019. National Database of Laws and Regulations: https://flk.npc.gov.cn/.

7. UNCITRAL Model Law on Electronic Commerce, 1996, and UNCITRAL Model Law on Electronic Signatures, 2001, as comparative background instruments, https://uncitral.un.org/.

8. Supreme People's Court of the People's Republic of China, judicial interpretations and guiding practice concerning contract disputes, online transactions, standard terms, and electronic evidence.

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Published

2026-07-09