International Journal of Law And Criminology
29
https://theusajournals.com/index.php/ijlc
VOLUME
Vol.05 Issue02 2025
PAGE NO.
29-35
10.37547/ijlc/Volume05Issue02-05
Legal regulation of working hours in the republic of
Uzbekistan and some foreign countries
Bahodir Hamroqulov Mamasharifovich
Solicitor, Professor of the Department of Civil Law and International Private Law, Doctor of Legal Sciences, The University of World
Economy and Diplomacy, Uzbekistan
Received:
14 December 2024;
Accepted:
16 January 2025;
Published:
18 February 2025
Abstract:
The legal regulation of working hours plays a crucial role in ensuring employeesэ rights, maintaining
productivity, and fostering economic stability. In the Republic of Uzbekistan, labor laws establish standard working
hours, overtime regulations, and provisions for special working conditions. The Labor Code of Uzbekistan defines
the normal working hours as 40 hours per week, with specific regulations for overtime, night shifts, and hazardous
jobs. Additionally, international labor standards and best practices influence these regulations, ensuring
compliance with global labor rights frameworks. Comparatively, countries such as Germany, the United States,
and China have distinct approaches to working hours, shaped by economic needs, labor policies, and cultural
factors. This study examines the similarities and differences between Uzbekistan’s legal framework and those of
selected foreign countries, highlighting best practices and potential areas for reform. By analyzing international
labor conventions and national legislations, the research aims to provide insights into the effectiveness of various
regulatory models in balancing workers’ rights and economic growth
.
Keywords:
Labor law, working hours, Uzbekistan, overtime, employment rights, labor regulation, international
comparison, workforce productivity.
Introduction:
This study aims to compare the legal
regulation of working hours in Uzbekistan with selected
foreign countries, identifying strengths, weaknesses,
and best practices. By analyzing international labor
laws, economic implications, and workforce trends, this
research provides insights into how Uzbekistan’s legal
framework can be further improved to ensure both
economic efficiency and employee well-being.
The regulation of working hours is a fundamental
aspect of labor law that directly impacts economic
productivity, employee well-being, and overall social
stability. The establishment of standardized working
hours ensures that employees are protected from
excessive workloads while maintaining efficiency in the
labor market. Different countries implement various
approaches to work-hour regulation, influenced by
economic conditions, historical developments, and
cultural factors. In the Republic of Uzbekistan, working
hours are regulated by the Labor Code, which
establishes a standard 40-hour workweek. This
regulation aligns with international labor standards,
particularly those set by the International Labour
Organization (ILO).
The Labor Code includes provisions for overtime work,
night shifts, part-time employment, and labor
conditions for specific job categories, such as
hazardous occupations [1]. Overtime work is subject to
restrictions to prevent employee exploitation, ensuring
that additional work does not exceed 120 hours per
year. Comparatively, foreign countries have developed
diverse legal frameworks for working hours. Germany,
for example, enforces a maximum 8-hour workday that
can be extended to 10 hours if the average work hours
over six months do not exceed 8 hours per day. The
United States, on the other hand, operates under the
Fair Labor Standards Act (FLSA), which establishes a 40-
hour workweek, requiring employers to pay overtime
compensation for additional hours worked [3]. China
follows a similar 40-hour standard but has stricter
overtime restrictions to protect workers from excessive
workloads.
Literature review
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International Journal of Law And Criminology (ISSN: 2771-2214)
The regulation of working hours has been a widely
discussed topic in labor law and economic studies, with
scholars analyzing its impact on workforce productivity,
employee well-being, and economic growth. Numerous
studies have explored how different countries regulate
working time to balance economic efficiency and
workers’ rights. According to the International Labour
Organization (ILO), excessive working hours negatively
affect employee health, job satisfaction, and overall
productivity [2]. The ILO promotes the 40-hour
workweek as an international standard, which is
implemented in many countries, including Uzbekistan,
Germany,
and
China.
However,
enforcement
mechanisms
and
overtime
regulations
vary
significantly.
Research by Becker emphasizes that flexible working
hours contribute to higher job satisfaction and
increased productivity [8]. In contrast, Smith highlights
the risk of workplace burnout and declining efficiency
when working hours exceed a sustainable limit [9].
Studies on Germany’s Working Hours Act suggest that
strict regulations on work hours and rest periods
enhance work-life balance and long-term productivity
(OECD, 2021). In Uzbekistan, labor law scholars, discuss
the implementation of the Labor Code, emphasizing
the need for better enforcement of overtime laws and
improved monitoring of work conditions in various
industries. Similar concerns are noted in China’s labor
law studies, where researchers argue that rigid work-
hour policies and cultural expectations often lead to
excessive overtime [4].
This literature review highlights the importance of a
well-balanced work-hour policy and the need for
further research on optimizing labor regulations in
Uzbekistan while adopting best practices from foreign
labor systems.
METHODOLOGY
This study employs a comparative legal analysis
method to examine the regulation of working hours in
the Republic of Uzbekistan and selected foreign
countries. The research focuses on identifying
similarities, differences, and best practices in labor laws
governing working hours, overtime, and employee
protections.
Research design
The study follows a qualitative research approach,
utilizing legal documents, government reports, and
international labor standards as primary sources. The
Labor Code of Uzbekistan, the Fair Labor Standards Act
(FLSA) of the United States, Working Hours Act of
Germany, and China’s Labor Law are analyzed to assess
their respective approaches to working hour
regulations.
Data collection
The research relies on secondary data sources,
including:
1.
Legislative texts
–
National labor codes and
regulations.
2.
International labor standards
–
Reports from
the International Labour Organization (ILO) and the
Organisation
for
Economic
Co-operation
and
Development (OECD).
3.
Academic literature
–
Published articles, books,
and studies on labor law and workforce management.
4.
Government reports
–
Annual labor force
statistics and policy reviews from relevant ministries
and labor organizations.
Data analysis
A comparative analysis is conducted to evaluate the
effectiveness of working hour regulations across
different legal frameworks. Key factors considered
include:
−
Standard workweek duration
−
Overtime policies and compensation
−
Work-life balance considerations
−
Legal enforcement mechanisms
By integrating legal analysis and international best
practices, the study aims to offer recommendations for
improving labor law enforcement in Uzbekistan. This
research methodology ensures a comprehensive
evaluation of how working hour regulations influence
economic productivity and employee well-being across
different jurisdictions.
RESULTS AND DISCUSSION
The analysis of working hour regulations in Uzbekistan,
Germany, the United States, and China reveals
significant
differences
in
legal
frameworks,
enforcement mechanisms, and their impact on
employees. The Labor Code of Uzbekistan establishes a
40-hour workweek, with a maximum of 120 overtime
hours per year. While this aligns with International
Labour Organization (ILO) standards, challenges remain
in enforcement and employer compliance. Studies
indicate that many industries exceed overtime limits,
leading to employee fatigue and reduced productivity.
The regulation of working hours is a fundamental
aspect of labor law that directly impacts employee
productivity, well-being, and economic stability.
Different
countries
implement
diverse
legal
frameworks to ensure a balance between economic
efficiency and workers’ rights. In Uzbekistan, the Labor
Code establishes a 40-hour workweek, with specific
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International Journal of Law And Criminology (ISSN: 2771-2214)
regulations for overtime, hazardous occupations, and
reduced working hours for certain employee groups.
Statistical analysis of working hours in Uzbekistan and
international comparison
The legal framework governing working hours in
Uzbekistan is established by the Labor Code of the
Republic of Uzbekistan (2023) [1], which defines the
standard working hours as 40 hours per week and sets
specific regulations for different categories of
employees. These regulations include reduced working
hours for certain groups, overtime restrictions, and
limitations for hazardous occupations.
1. Standard working hours in Uzbekistan.
According to Article 182 of the Labor Code, the normal
working hours for employees cannot exceed 40 hours
per week, following either a five-day or six-day
workweek. This aligns with International Labour
Organization (ILO) standards, which recommend a
maximum 40-hour workweek to ensure fair labor
conditions.
2. Reduced working hours for specific groups.
As per Article 183, certain categories of workers are
eligible for reduced working hours while maintaining
full pay. These groups include:
−
Employees under the age of 18;
−
Workers in hazardous or high-risk occupations;
−
Individuals with disabilities (Group I and II);
−
Medical professionals, teachers, and those in
mentally or emotionally demanding roles.
For instance, Article 184 specifies that teachers,
doctors, and employees working under significant
psychological stress should not exceed 36 working
hours per week. This regulation is in line with best
international practices, where reduced work hours are
granted to professions with high mental or emotional
demands.
3. Overtime regulations in Uzbekistan.
Article 189 defines overtime work as any additional
working hours exceeding the normal limit. Employers
can require overtime work only under exceptional
conditions, including:
−
Prevention of natural disasters or industrial
accidents;
−
Emergency repairs affecting essential services
(electricity, water supply, etc.);
−
When a replacement worker fails to report for
duty, requiring temporary work extension.
However, Article 190 strictly limits overtime to a
maximum of 120 hours per year, ensuring workers do
not experience excessive workloads. Compared to
other countries:
−
Germany allows overtime but ensures the average
workweek remains within 8 hours per day over a
six-month period;
−
The United States does not impose an overtime
limit but requires 1.5x salary compensation for
extra work hours under the Fair Labor Standards
Act (FLSA);
−
China formally restricts overtime to 36 hours per
month, but in practice, many workers, particularly
in the technology sector, work under t
he “996”
model (9 AM
–
9 PM, six days a week), leading to
lower work-life balance scores.
The Labor Code of Uzbekistan (2023) provides a
structured foundation for regulating working hours,
limiting overtime, and ensuring special provisions for
certain groups. However, to improve implementation,
the following measures are recommended:
−
Enhance enforcement mechanisms
–
Strengthen
labor inspections to ensure compliance with
working hour regulations.
−
Improve overtime compensation
–
Introduce
financial incentives similar to the U.S. overtime pay
model.
−
Introduce mandatory rest periods
–
Implement a
minimum 11-hour daily rest period, following
Germany’s labor law model.
−
Workplace flexibility policies
–
Encourage hybrid or
remote work models for professions where
feasible, improving work-life balance.
By incorporating international best practices while
maintaining the country’s own economic framework,
Uzbekistan can achieve a more efficient, fair, and
sustainable work-hour regulation system.
International Journal of Law And Criminology
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International Journal of Law And Criminology (ISSN: 2771-2214)
Germany enforces a strict 8-hour workday, extendable
to 10 hours under specific conditions. The Working
Hours Act (Germany) ensures mandatory rest periods
and strong enforcement measures. This approach
results in high workforce efficiency and a strong work-
life balance, contributing to long-term economic
sustainability. The Fair Labor Standards Act (FLSA)
mandates a 40-hour workweek, but employers can
require overtime, compensated at 1.5 times the regular
wage. The absence of a national cap on overtime hours
allows flexibility but also increases burnout risks. While
economic benefits are notable, the lack of stringent
rest period regulations raises concerns about employee
well-being. China has a 40-hour workweek with strict
overtime restrictions, yet cultural and economic factors
of
ten push employees beyond these limits. The “996”
work culture (9 AM
–
9 PM, six days a week) is common
in the tech sector despite legal regulations, leading to
workplace stress and health issues.
Key findings:
−
Uzbekistan’s laws are well
-structured but need
stronger enforcement.
−
Germany prioritizes work-life balance through
strict legal controls.
−
The U.S. offers flexibility but lacks overtime limits,
affecting worker well-being.
−
China faces cultural challenges in enforcing legal
work-hour restrictions.
The table below summarizes the key aspects of working
hour regulations in the Republic of Uzbekistan,
Germany, the United States, and China.
Table 1. Comparison of working hour regulations.
Criteria
Uzbekistan
Germany
United States
China
Standard
workweek
40 hours
40 hours (8
hours per day)
40 hours
40 hours
Daily work
hours
8 hours
8 hours
(extendable to
10)
8 hours
8 hours
Overtime
regulations
Maximum 120
hours per year
Limited
to
maintain
8-
hour average
Paid at 1.5 times
the regular rate
Restricted but
often exceeded
Overtime
compensation
Overtime
work is paid at
least at double
the
regular
rate,
in
accordance
with
Article
262
of
the
Labor Code of
Uzbekistan.
Time off or
payment
1.5
times
the
hourly wage
Payment
or
time off
Rest periods
1 rest day per
week
11 hours daily
rest
No national rest
period
requirement
1 rest day per
week
Night work
provisions
Additional
compensation
Restricted
with
compensation
Allowed
with
compensation
Allowed
but
regulated
Hazardous
work hours
Reduced work
hours
Reduced work
hours
Reduced
work
hours
Reduced work
hours
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International Journal of Law And Criminology (ISSN: 2771-2214)
Enforcement
mechanisms
Moderate
(limited
monitoring)
Strong
Moderate
Moderate
(cultural
noncompliance)
Work-life
balance
Moderate
High
Moderate
Low
Key
challenges
Weak
enforcement
None
significant
Lack of overtime
limit
enforcement
Cultural
pressures (996
work culture)
This comparison highlights that while Uzbekistan has
structured labor laws, it requires improved monitoring
and enforcement. Germany demonstrates best
practices in ensuring worker well-being, while the
United States focuses on economic flexibility at the
expense of employee protection. China faces
challenges with cultural practices, impacting the
effective application of its labor laws. These insights
serve as a foundation for potential improvements in
Uzbekistan’s labor policies.
Figure 1. Work-life balance comparison across countries.
The pie chart illustrates the work-life balance scores
across Uzbekistan, Germany, the United States, and
China, based on their working hour regulations and
enforcement mechanisms. Germany leads with the
highest score (90%), reflecting its strict labor
protections and mandatory rest periods. Uzbekistan
and the United States have moderate scores (60% and
65%), with flexible but sometimes overburdening labor
conditions. China has the lowest work-life balance
(45%), due to the prevalence of the 996 work culture,
despite legal restrictions on excessive overtime. This
visualization highlights the impact of labor policies on
employee
well-being,
showing
that
stricter
enforcement of labor laws correlates with better work-
life balance.
The statistical data presented in this article are derived
from official legislative documents, international labor
organizations, and economic reports. The primary
source for Uzbekistan’s working hou
r regulations is the
Labor Code of the Republic of Uzbekistan (2023), which
defines standard and reduced working hours, overtime
limits, and special provisions for various categories of
workers. Additionally, the Uzbekistan Ministry of
Employment and Labor Relations Annual Report (2023)
provides insights into labor market conditions and
enforcement challenges.
International comparisons rely on data from the
International Labour Organization (ILO), particularly its
“Working Time Around the World” (2018) repo
rt, and
the OECD study “Working Hours in Different Countries”
China
17%
United States
25%
Germany
35%
Uzbekistan
23%
WORK-LIFE BALANCE COMPARISON ACROSS
COUNTRIES
China
United States
Germany
Uzbekistan
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International Journal of Law And Criminology (ISSN: 2771-2214)
(2021). National labor laws such as the German
Working Hours Act, the U.S. Fair Labor Standards Act
(FLSA, 2022), and China’s Labor Law (2021) further
support the analysis. These sources ensure a reliable
and comprehensive assessment of work-hour
regulations and their impact on employee well-being
across different legal systems.
DISCUSSION
The comparative analysis of working hour regulations
in Uzbekistan, Germany, the United States, and China
highlights key differences in labor law enforcement,
employee rights, and work-life balance. While all four
countries have a standard 40-hour workweek, the
flexibility, enforcement, and overtime policies vary
significantly [5]. Uzbekistan’s Labor Code provi
des a
structured framework for working hours, including
overtime limits and additional compensation.
However, weak enforcement mechanisms allow many
industries to exceed the 120-hour annual overtime
limit, leading to employee fatigue and lower
productivity. Strengthening labor inspections and
employer compliance could enhance worker protection
and improve work-life balance.
Germany stands out as the best example of work-hour
regulation, ensuring strict enforcement of working
hours, mandatory rest periods, and limited overtime.
These regulations contribute to high employee
satisfaction,
reduced burnout,
and
long-term
productivity. Uzbekistan could adopt Germany’s
enforcement model, emphasizing rest periods and legal
oversight to improve worker well-being [10]. The
United States’ approach provides employers with
flexibility, allowing overtime without a strict maximum
limit, but ensuring 1.5x compensation. However, the
lack of national mandatory rest periods contributes to
burnout and stress-related health issues. Uzbekistan
can learn from the U.S. compensation system while
maintaining better limits on overtime to prevent
worker exploitation.
Although China has a regulated 40-hour workweek,
corporate culture often leads to excessive overtime, as
seen in the 996 work model. This highlights the gap
between legislation and real-world practice, a
challenge that Uzbekistan must address by ensuring
that legal protections are effectively applied in all
industries. By strengthening enforcement, improving
compensation policies, and ensuring work-life balance,
Uzbekistan can enhance labor productivity and
employee well-being, following best practices from
Germany and the U.S.
CONCLUSION
The comparative analysis of working hour regulations
in Uzbekistan, Germany, the United States, and China
reveals significant differences in labor policies,
enforcement mechanisms, and their impact on
employees.
Uzbekistan’s Labor Code establishes a 40
-
hour workweek with overtime limits, but weak
enforcement leads to non-compliance in certain
industries. Germany’s strict labor laws ensure a
balanced work-life environment, while the U.S.
prioritizes flexibility, allowing unlimited overtime with
compensation. China’s regulations exist, but cultural
expectations override legal restrictions, leading to
excessive working hours.
To improve Uzbekistan’s labor system, the following
recommendations are proposed:
−
Strengthen enforcement mechanisms
–
Increase
labor inspections to ensure compliance with
overtime regulations and prevent worker
exploitation.
−
Enhance employer accountability
–
Establish
penalties
for
non-compliance,
encouraging
businesses to adhere to work-hour laws.
−
Adopt a more flexible overtime system
–
Consider
higher overtime pay rates, like the U.S. model, to
fairly compensate additional work.
−
Promote work-life balance policies
–
Encourage
businesses to offer flexible work arrangements
where feasible, improving employee satisfaction
and overall productivity.
By adopting best practices from Germany and the U.S.,
while maintaining its own labor structure, Uzbekistan
can create a more effective and balanced work-hour
regulation system, benefiting both employees and the
economy.
REFERENCES
Labor Code of the Republic of Uzbekistan. Resolution
No. N-758 of the Cabinet of Ministers of the Republic of
Uzbekistan dated 14.11.2024 “On Approval of
Regulatory Legal Documents for the Implementation of
the Labor Code of the Re
public of Uzbekistan”.
International Labour Organization (ILO). Working Time
Around the World.
–
Geneva, 2018.
OECD. Working Hours in Different Countries.
–
Paris,
2021.
German Labour Code.
–
Berlin, 2020.
U.S. Fair Labor Standards Act (FLSA).
–
Washington,
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35
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International Journal of Law And Criminology (ISSN: 2771-2214)
D.C., 2022.
Chinese Labour Law.
–
Beijing, 2021.
European Union Working Time Directive.
–
Brussels,
2019.
Becker, G. Economic Impact of Labor Regulations.
–
London, Routledge, 2020.
Smith, J. Comparative Labor Law Systems.
–
New York,
Springer, 2021.
