Inviolability of advocates and compliance officers: what Law No. ZRU-1182 changed and what it did not

On 14 October 2026 the President of Uzbekistan signed Law No. ZRU-1182. It amends the Criminal Code, the Criminal Procedure Code (CPC), the Code of Administrative Liability and the Law on Operational and Investigative Activity. The law was officially published on 15 October and took effect the same day.

The CPC now has a new Chapter 59¹, "Proceedings concerning persons with inviolability or immunity". Alongside members of parliament, judges and prosecutors, the list of persons with inviolability names two further groups: advocates, and staff of the compliance and anti-corruption internal control units of state bodies and organisations (Article 546³).

What is new for advocates

Advocate inviolability itself is not new. Article 6 of the Law on Guarantees of Advocacy and Social Protection of Advocates has long declared inviolable the advocate's person, home, office, means of communication and documents. Only the Prosecutor General and the prosecutors of Karakalpakstan, the regions and Tashkent city could open a criminal case against an advocate, and searches, interception of communications, compelled appearance and detention also required their sanction.

Law ZRU-1182 has written these guarantees into the CPC itself and attached concrete consequences to them:

Detention: a person with inviolability may not be detained and taken to a law enforcement body, except for up to three hours when caught in the act or immediately afterwards (Article 221(1) of the CPC). Otherwise, detaining an advocate requires the consent of the prosecutors listed above (Article 546⁷).
Searches and interception: entering an advocate's home, office or vehicle, searching them, intercepting communications and seizing documents or mail require the sanction of the same prosecutors or a court order. These rules do not apply when the advocate is caught in the act (Article 546¹⁰).
Consequences of a breach: procedural decisions taken in breach of the chapter are unlawful and must be set aside, and the evidence obtained is inadmissible and cannot ground a charge. A case opened by an official without authority must be discontinued (Article 546¹¹).
Criminal liability: a new Article 230³ of the Criminal Code makes it an offence to knowingly and unlawfully detain, compel the appearance of, or carry out investigative actions against a person with inviolability. The penalty is three to five years' restriction or deprivation of liberty, rising to five to eight years' imprisonment for repeat or group offences, violence, fabricated evidence, or where the breach takes the form of remand in custody or criminal prosecution.

Until now, the guarantee sat in a special law and the consequences of breaching it had to be inferred from general rules. Both the consequences and a dedicated criminal offence are now written directly into the CPC and the Criminal Code.

The point that matters most for clients

Article 546¹¹ contains a sentence that is easy to miss: the consequences of a breach apply only to the person whose inviolability was breached.

In practice, suppose an advocate's office is searched without a sanction and a client's documents are seized. Under Article 546¹¹ that evidence is inadmissible against the advocate. The special rule does not, by itself, protect the client. The client's defence must rely on two general rules instead: Article 95¹ of the CPC, which excludes evidence obtained by unlawful means or in breach of the CPC, and Article 7 of the Law on Guarantees of Advocacy, which prohibits demanding from an advocate any material covered by legal professional privilege.

There is no court practice on this question yet, and it is likely to become the most contested one.

Compliance officers are protected too

In our article of 14 October we described how the new model regulation shields internal control staff from dependence on management. Law ZRU-1182 adds a procedural layer:

only the Prosecutor General can open a criminal case against them (Article 546⁵);
searches, interception and seizure of documents require the Prosecutor General's written permission or a court order (Article 546¹⁰);
detention, remand in custody and questioning as a witness or suspect require notice to the Prosecutor General, and this protection continues for two years after they leave the job (Articles 546⁷, 546⁸ and 546¹⁰).

One question remains open. The model regulation treats companies with a state share of 50 per cent or more as "state organisations". The law does not define the term. Whether the internal control staff of state-owned companies are covered will have to be settled in practice.

Practical steps

Mark correspondence and documents exchanged with your advocate as privileged and keep them separate from other corporate records.
If investigative actions begin against an advocate, check that a sanction or court order exists and who signed it, and have this recorded in the protocol.
If detention is based on being caught in the act, make sure the exact time is recorded: the three-hour limit runs from it.
If material seized from an advocate is used against the client, apply to exclude it under Article 95¹ of the CPC and legal professional privilege.
Heads of state bodies and organisations: personnel measures against an internal control officer must be agreed with the Agency, and procedural actions against them now involve the Prosecutor General. Support any complaint about their work with documents.

The law turns the protection of advocates and internal control officers from a declaration into a working mechanism. How it works will now depend on the courts. If you have questions, the partners of Business Lawyers Group are available.

What is new for advocates

The point that matters most for clients

Compliance officers are protected too

Practical steps

Sources

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