Civil Law Regulation of Prosuming Activity in the Republic of Uzbekistan through Comparative Legal Analysis and Legislative Reform Proposals

Abstract

This study examines the civil law regulation of prosuming activity, the combined production and consumption of electricity by households and small businesses in the Republic of Uzbekistan. Using doctrinal and functional comparative methods, the study analyses Uzbek civil and energy legislation alongside the regulatory models of the European Union, Germany, the United States, and the Commonwealth of Independent States. The research finds that Uzbek law enables the sale of surplus electricity by individuals but does not define the prosumer as a legal category, leaves the civil law nature of surplus-sale contracts uncertain, and creates risks of qualifying household generation as entrepreneurial activity. The article proposes legislative amendments, including a statutory definition of the prosumer, a presumption of non-entrepreneurial character within capacity limits, a public model contract for the purchase of surplus electricity, extended consumer protection, and a framework for jointly acting prosumers, aligning Uzbek legislation with international best practice