Анализ основ организации деятельности органов исполнительной власти Узбекистана и зарубежных государств

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Analysis of the basis of organizing the activities of
executive authority bodies of Uzbekistan and foreign
states

Bekhzodbek IBROKHIMOV

1

Tashkent State University of Law

ARTICLE INFO

ABSTRACT

Article history:

Received April 2025

Received in revised form

15 May 2025
Accepted 25 May 2025

Available online

15 June 2025

This article provides a comparative analysis of the

foundations of the organization of the activities of the executive

authorities of the Republic of Uzbekistan and a number of

foreign countries

–

including Great Britain, the USA, Germany

and France. The executive branch

–

as an important branch of

state power

–

performs the tasks of ensuring the

implementation of laws, implementing state policy in practice

and providing services to citizens. Presidential decrees and

resolutions adopted in Uzbekistan in recent years, such as
PF

–

49 (2024), PQ

–

447 (2022), and PF

–

14 (2023), set out

measures to modernize, digitize, ensure openness and increase

efficiency of this branch. Foreign experience

–

in particular,

parliamentary oversight, federal government, and specific

methods of presidential-parliamentary balance

–

allow us to

draw important conclusions for Uzbekistan. According to the

results of the comparative analysis, ensuring a balance of

powers in governance, directing executive activities to the

interests of citizens, and strengthening political and legal
responsibility are of urgent importance.

2181-1415/

©

2025 in Science LLC.

DOI:

https://doi.org/10.47689/2181-1415-vol6-iss5/S-pp

82-89

This is an open access article under the Attribution 4.0 International
(CC BY 4.0) license (https://creativecommons.org/licenses/by/4.0/deed.ru)

Keywords:

executive branch,

public administration,

law enforcement,
Presidential decree,

parliamentary oversight,
management efficiency,
digital governance,

foreign experience,

balance of powers,

public policy,

comparative analysis,

legal reforms.

1

Master's degree student, Tashkent State University of Law. E-mail: behzodbekibrohimov00@gmail.com

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O‘zbekiston va xorijiy davlatlarning ijro etuvchi hokimiyat

organlari faoliyatini tashkil etish asoslari tahlili

ANNOTATSIYA

Kalit so‘zlar

:

Ijro etuvchi hokimiyat,
davlat boshqaruvi,

qonun ijrosi,

Prezident farmoni,
parlament nazorati,
boshqaruv samaradorligi,

raqamli boshqaruv,

xorijiy tajriba,

vakolatlar muvozanati,
davlat siyosati,

taqqosiy tahlil,

huquqiy islohotlar.

Mazkur maqolada O‘zbekiston Respublikasi hamda bir qator

xorijiy davlatlar

–

jumladan, Buyuk Britaniya, AQSH, Germaniya

va Fransiya

–

ijro etuvchi hokimiyat organlari faoliyatini tashkil

etish asoslari qiyosiy tahlil qilinadi. Ijro hokimiyati

–

davlat

hokimiyatining muhim tarmog‘i sifatida –

qonunlar ijrosini

ta’minlash, davlat siyosatini amaliyotga tatbiq etish va

fuqarolarga xizmat ko‘rsatish vazifalarini bajaradi. O‘

zbekistonda

so‘nggi yillarda qabul qilingan PF–

49 (2024), PQ

–

447 (2022), va

PF

–

14 (2023) kabi Prezident farmon va qarorlarida ushbu

tarmoqni modernizatsiya qilish, raqamlashtirish, ochiqlikni

ta’minlash va samaradorlikni oshirish choralari belgilandi.

Xorijiy tajribalar

–

xususan, parlament nazorati, federal

boshqaruv, hamda prezidentlik-parlamentlik muvozanatining

o‘ziga xos usullari –

O‘zbekiston uchun muhim xulosalar

chiqarishga imkon beradi. Taqqosiy tahlil natijalariga ko‘ra,

boshqaruvda vakolatlar bal

ansini ta’minlash, ijro faoliyatini

fuqarolar manfaatlariga yo‘naltirish va siyosiy

-huquqiy

mas’uliyatni kuchaytirish dolzarb ahamiyat kasb etadi.

Анализ основ организации деятельности органов
исполнительной власти Узбекистана и зарубежных
государств

АННОТАЦИЯ

Ключевые слова:

исполнительная власть,

государственное
управление,
правоохранительная

деятельность,

указ Президента,
парламентский контроль,

эффективность
управления,

цифровое управление,

зарубежный опыт,

баланс властей,
государственная
политика,

сравнительный анализ,

правовые реформы.

В статье проводится сравнительный анализ основ

организации деятельности органов исполнительной
власти в Республике Узбекистан и ряде зарубежных стран,

в том числе Великобритании, США, Германии и Франции.

Исполнительная власть, как важная ветвь государственной

власти, отвечает за обеспечение исполнения законов,
реализацию государственной политики и предоставление

услуг гражданам. В принятых в Узбекистане за последние
годы указах и постановлениях Президента, таких как

ПФ–49 (2024), ПП–447 (2022) и ПФ–14 (2023), изложены

меры по модернизации, цифровизации, обеспечению
открытости и повышению эффективности в этой сфере.

Зарубежный опыт, в частности парламентский надзор,

федеральное

управление

и

конкретные

методы

президентско

-

парламентского баланса, позволяет нам

сделать важные выводы для Узбекистана. По результатам

сравнительного анализа актуальное значение имеют

обеспечение баланса властей в управлении, ориентация

деятельности исполнительной власти на интересы граждан,
усиление политической и правовой ответственности.

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INTRODUCTION

In the modern era of global political transformation and governance

modernization, the structure and functioning of executive authorities play a decisive role
in ensuring the efficiency of public administration. The executive branch, as one of the
three fundamental pillars of state power, stands at the core of translating legislative
intentions into practical implementation. Across different countries, its structure,
principles of operation, and level of independence vary depending on political systems,
historical traditions, and constitutional norms. The comparative study of the organization
of executive power in Uzbekistan and foreign countries such as the United States, the
United Kingdom, Germany, and France reveals both universal features and distinct
national characteristics.

Uzbekistan, since gaining independence in 1991, has undergone profound

transformations in its public administration system, particularly in the sphere of
executive power. Initially modeled in a centralized post-

Soviet context, the country’s

executive institutions have progressively evolved toward greater efficiency,
transparency, and accountability. Notably, under the leadership of President
Shavkat Mirziyoyev, significant reforms have been implemented to modernize the
executive branch. Presidential Decree No. PF

–

49 (2024), Resolution No. PQ

–

447 (2022),

and Presidential Decree No. PF

–

14 (2023) have set the foundation for reducing

bureaucratic barriers, digitizing executive functions, decentralizing authority to local
levels, and enhancing public service quality [1].

Conversely, in established democracies like the United States and the United

Kingdom, the executive authority is shaped by long-standing traditions of the separation
of powers and checks and balances. The U.S. presidential system grants significant
autonomy to the President and the federal agencies, with a robust mechanism of
congressional oversight. The UK, functioning under a parliamentary monarchy, entrusts
executive powers to the Prime Minister and Cabinet, who are directly accountable to
Parliament. In both cases, the executive is constrained and guided by strong legal and
institutional frameworks that ensure responsiveness and public accountability [2].

In the case of Germany and France, executive power operates within a hybrid

model. Germany's chancellor-led parliamentary system emphasizes federalism and

intergovernmental coordination, while France’s semi

-presidential system grants strong

executive powers to the President, complemented by a Prime Minister accountable to the
legislature. These systems balance centralized decision-making with institutional
accountability and public oversight, which are crucial for policy effectiveness and
legitimacy.

This article seeks to analyze the theoretical and organizational foundations of the

executive authorities in Uzbekistan and selected foreign states, drawing attention to
structural principles, legal frameworks, and practical governance approaches. The goal is
to identify best practices, highlight existing challenges, and formulate relevant
recommendations that could contribute to the ongoing reform of executive governance in
Uzbekistan. By examining international models and their adaptation to national contexts,
the paper aims to enrich the discourse on public sector development and strengthen
institutional capacity for effective governance in line with democratic principles and
sustainable development goals.

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LITERATURE ANALYSIS AND METHODOLOGY

Asrorov B.B. In his study, the author describes the reforms in the optimization of

executive authorities, the role of optimization in the political life of the country, the
analysis of the legislation of foreign countries, and proposals and recommendations
based on these studies and analyses [3].

Miradinov T. and Omirzakov R. The authors' studies touch upon the system of

executive authorities of the Republic of Uzbekistan and the powers of ministries in the
field of environmental state management as the main link of this system, state
management in the environmental sphere and the reforms carried out in this area in
recent years. In addition, the article specifically addresses the powers of the Ministry of
Ecology, Environmental Protection and Climate Change, and describes the brief history of
the ministry, its main tasks and its role in the socio-economic life of the country [4].

RESULTS

The analysis of the organizational foundations of executive authorities in

Uzbekistan and selected foreign countries reveals significant structural and functional
differences rooted in political systems, legal traditions, and historical development.
Despite these distinctions, the comparative framework offers valuable insights for
improving executive governance practices, especially in transitional or reforming states
like Uzbekistan. This section provides a systematic evaluation of the institutional design,
power distribution, and governance efficiency of executive bodies in the United States,
Germany, France, and the United Kingdom, juxtaposed with the ongoing reforms in
Uzbekistan.

In

Uzbekistan

, the executive authority is predominantly centralized and is headed

by the President, who is both the head of state and the de facto leader of the executive
branch. According to the 2023 amendments to the Constitution and key presidential
decrees such as PF

–

49 (2024), PF

–

14 (2023), and PQ

–

447 (2022), significant steps have

been taken to redefine the scope of executive functions, reduce overlapping duties, and
increase transparency through the creation of an open registry of executive powers.
However, issues such as bureaucratic redundancy, limited decentralization, and
underdeveloped public accountability mechanisms remain prevalent. The President
appoints the Prime Minister and directly oversees the Cabinet of Ministers, thus
reinforcing a top-down administrative structure. Although public administration reform
has emphasized digital governance and citizen-centric services, the functional
independence of local executive branches is still constrained [5].

In contrast,

the United States

employs a presidential model characterized by a clear

separation of powers and checks and balances. The President, as the head of the
executive, is independently elected and possesses wide-ranging powers, including the
appointment of federal officials, command over the armed forces, and veto authority over
legislation. However, executive decisions are subject to judicial review and congressional
oversight. Unlike Uzbekistan, where executive and legislative functions often intertwine
under presidential authority, the U.S. system ensures horizontal accountability and limits
executive overreach. Moreover, the U.S. federal structure grants states substantial
autonomy, enabling localized implementation of national policies while allowing
variation based on regional needs. This decentralized design promotes adaptive
governance but may slow uniform policy execution.

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Germany

offers a hybrid model that blends federalism with parliamentary oversight.

The executive authority lies primarily with the Chancellor, who is elected by the Bundestag

(parliament) and leads the federal government. The President holds a ceremonial role.

Germany’s system emphasizes the principle of subsidiarity, wherein executive tasks are

distributed across federal, stat

e (Länder), and municipal levels. This layered approach,

supported by constitutional guarantees, encourages regional decision-making and

institutional autonomy. Compared to Uzbekistan, where central authority dominates

decision-

making processes, Germany’s

model fosters cooperation and delegation, thus

enhancing governance efficiency. Furthermore, Germany’s administrative courts provide

robust legal remedies for unlawful executive action, a feature that Uzbekistan is still

working to strengthen under its 2020

–

2025 judicial reforms.

France

, a semi-presidential republic, features dual executive authority comprising

the President and the Prime Minister. The President is directly elected and wields

significant powers in foreign policy and national defense, while the Prime Minister

handles domestic administration and coordinates cabinet ministries. This balance of

power depends largely on whether the President’s party holds a majority in the National

Assembly (cohabitation). Compared to Uzbekistan’s centralized exe

cutive, France

demonstrates a functional division of executive responsibilities, offering a dynamic

model where executive leadership shifts in response to electoral outcomes. Moreover,

France has implemented strong mechanisms of administrative law and public service

professionalism, which ensures that executive functions remain aligned with rule-of-law

principles. Uzbekistan, by contrast, still faces challenges related to merit-based civil

service development and executive transparency.

The

United Kingdom

, with its parliamentary monarchy, illustrates a unique form of

executive organization. Here, executive power is formally vested in the monarch but

exercised by the Prime Minister and the Cabinet, who are members of Parliament. The

executive is directly accountable to the legislature, and its legitimacy depends on

retaining the confidence of the House of Commons. This model enables a high degree of

legislative control over executive decisions, contrasting sharply with Uzbekistan’s

system, where executive decisions are primarily initiated by the presidency and

parliamentary oversight is limited. The UK’s model demonstrates the benefits of

responsive governance, policy agility, and institutional maturity. Nonetheless, some

critics argue that this model may suffer from excessive politicization, especially during

majority governments [6].

The comparative analysis indicates that while Uzbekistan’s executive system has

undertaken major reforms to improve efficiency, digital governance, and legal

accountability, it remains highly centralized. Lessons drawn from the decentralized and

accountable systems of the U.S., Germany, France, and the UK can inform further

improvements. Adopting principles such as functional separation of powers, enhanced

judicial review, and decentralized decision-making could significantly enhance the

responsiveness and transparency of executive governance in Uzbekistan. Future reform

strategies may benefit from integrating international best practices tailored to local

socio-political contexts.

DISCUSSION

The organization of executive authority plays a pivotal role in ensuring the

efficient functioning of any state apparatus. The executive branch is tasked with

translating legislative frameworks into practical policies and overseeing their

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implementation across multiple domains of governance. In Uzbekistan, as in many other

countries, the structure and functions of executive bodies are undergoing reform to meet

the evolving needs of public administration, technological development, and democratic

accountability. This discussion explores the current organizational foundations of

executive authority in Uzbekistan, compares them with foreign models, and evaluates

both strengths and areas needing improvement.

Uzbekistan follows a centralized presidential system in which the President serves

as both the head of state and the highest executive authority. The Cabinet of Ministers

regional governors and sectoral ministries implement state policy in accordance with the

President’s direct

ives. According to Article 98 of the Constitution, the Cabinet is

accountable to both the President and the parliament. However, unlike parliamentary

systems in countries like Germany and the UK, Uzbekistan’s executive branch exercises

wide-ranging unilateral authority with relatively limited parliamentary oversight.

Recent reforms have focused on improving institutional performance. For instance,

Presidential Decree PF

–

49 (2024) introduced Key Performance Indicators (KPIs) to

measure the efficiency of executive leaders. PQ

–

447 (2022) emphasized the streamlining

of overlapping mandates, strengthening inter-agency coordination, and reducing

bureaucratic inertia. Moreover, the creation of an open registry for executive functions

(Decree No. 796, 2023) enhances transparency and public accountability. These

developments signal Uzbekistan’s commitment to modernizing its executive structure in

line with global governance trends [7].

Comparatively, in the Anglo-Saxon model, as seen in the United Kingdom and the

United States, executive power is either derived from parliamentary authority or

operates independently but under robust institutional checks. In the UK, the Prime

Minister is drawn from the majority party in Parliament and is accountable to it, while in

the U.S., the President, although not accountable to Congress in day-to-day matters,

operates within a system of checks and balances. In Germany’s federal

-parliamentary

system, the Chancellor is elected by the Bundestag and is subject to regular

parliamentary scrutiny. France represents a hybrid presidential-parliamentary system,

where the President appoints the Prime Minister, but executive powers are more

centralized.

These models reflect differing levels of decentralization, division of powers, and

mechanisms

of accountability. For example, Germany’s federal structure grants its states

(Länder) considerable autonomy in implementing national laws. This ensures greater

responsiveness to local needs and mitigates the risks of over-centralization. In contrast,

Uzb

ekistan’s model still retains a high degree of vertical integration, with limited local

autonomy, particularly in budget formation and policy execution.

Nevertheless, Uzbekistan has taken steps to bridge this gap. The empowerment of

local executive authorities, reforms in civil service recruitment, and digitalization of

administrative services are positive trends. Notably, the 2022

–

2026 Development

Strategy outlines objectives to enhance professionalism, transparency, and public

engagement in executive governance. However, challenges remain. These include

functional overlaps between central and regional agencies, insufficient delegation of

fiscal authority, and slow adaptation to digital platforms in some regions [8].

International best practices emphasize participatory governance, regular

performance audits, and decentralization of power as key drivers of executive

effectiveness. Uzbekistan can draw lessons from Germany's regional subsidiarity, the

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UK's parliamentary oversight mechanisms, and the U.S.'s emphasis on constitutional

checks. However, reforms must be tailored to local political culture, administrative

capacity, and socio-economic context.

The comparative analysis suggests that while Uzbekistan has made commendable

strides in modernizing its executive authority, further integration of international
principles

–

such as stronger legislative scrutiny, functional differentiation, and local

empowerment

–

will be essential for ensuring efficiency, responsiveness, and democratic

governance in the long term.

CONCLUSION

The analysis of the executive power institutions in Uzbekistan and selected foreign

countries reveals both significant similarities and striking differences in the structure,
functions, and operational mechanisms of executive bodies. Uzbekist

an’s executive

authority operates under a presidential system with a strong centralized governance
framework. The President serves as both the head of state and the highest executive
authority, shaping domestic and foreign policies and overseeing the gover

nment’s day

-

to-day functioning through the Cabinet of Ministers. The legal foundation of this system is
anchored in the Constitution of the Republic of Uzbekistan and further reinforced by a
number of presidential decrees and legislative acts, such as the PF

–

49 Presidential

Decree (March 13, 2024), which introduced performance-based evaluation for executive
bodies, and PQ

–

447 (December 21, 2022), aimed at structural reforms of the executive

apparatus.

In contrast, countries such as the United States and the United Kingdom follow

different models. The U.S. employs a presidential system based on the principle of
separation of powers, where the executive (President) operates independently of the
legislative branch. The UK, on the other hand, operates a parliamentary system where the
Prime Minister, as the head of government, derives authority from the legislative branch
and is held accountable to it. Germany and France offer hybrid or semi-presidential
models: Germany operates within a federal and parliamentary structure with a
Chancellor who is elected by the Bundestag, while France combines elements of
presidential and parliamentary systems, with a President holding significant powers in
foreign policy and national security.

From these models, key lessons emerg

e for Uzbekistan’s ongoing reforms. Notably,

the principle of checks and balances remains a central theme in foreign systems.
In Germany and the UK, executive bodies are subject to rigorous parliamentary scrutiny,

which enhances accountability and prevents abuse of power. France’s model underscores

the importance of balancing executive assertiveness with parliamentary legitimacy.
The U.S. system, despite strong presidential powers, embeds extensive judicial and
congressional oversight to restrain unilateral executive action.

Uzbekistan has made significant strides in modernizing its executive structure

by promoting transparency, digital governance, and public engagement. The

implementation of the “Unified Register of Executive Functions” (2024) marks a

significant move toward reducing bureaucratic overlap and clarifying institutional
responsibilities. The country is also expanding the role of local executive authorities,
especially through initiatives such as the appointment of district-level Presidential
assistants and the introduction of performance indicators to assess their contributions to
regional development.

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However, several challenges persist. The over-centralization of decision-making

processes often limits the autonomy and effectiveness of local governments. While the
appointment of hokims (governors) by presidential decree ensures loyalty and alignment
with national policy, it may also hinder responsiveness to local needs. Furthermore,

unlike in Germany’s federal system, Uzbekistan lacks a clear decentralization fram

ework,

which restricts regional innovation and adaptability.

A comparative study of executive governance highlights the need for Uzbekistan to

pursue a balanced model that ensures strong national leadership while empowering local
governments and reinforcing accountability mechanisms. Drawing from international
best practices

–

such as Germany’s federal structure, the UK’s parliamentary scrutiny,

and France’s institutional balance

–

Uzbekistan can develop a more resilient and

participatory executive governance system. Continued legal reforms, public sector
digitization, and civil service professionalization will be essential for enhancing the
effectiveness, responsiveness, and legitimacy of executive institutions in the years to
come. This evolving framework will not only strengthen public trust in government but
also support sustainable development and democratic consolidation in the New
Uzbekistan.

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