Domestic law and policy

Tajikistan does not yet have a single, consolidated digital ID law. Instead, there are certain laws which are relevant to digital identity. For example, The Law About The Electronic Document (2014) sets the legal basis for electronic documents.^[17] It requires that such documents contain identifying details and include electronic digital signatures or other means of verifying the originator.^[18] It equates electronic documents with physical documents for legal purposes and governs their creation, processing, transfer and storage.^[19]

The government adopted a ‘Concept of the Digital Economy’, a framework which includes: creating a public system to identify entities of information relations focused on the provision of digital services, providing authorised access to information, and establishing a Single Public Services Portal as part of the transition to digital government.^[20] It envisages integration of departmental information systems through a national platform and cloud infrastructure.^[21]

In 2025, based on a resolution and implementing order, the government began shifting pensioners to a digital identification system based on facial recognition (Face ID), requiring pensioners to complete biometric verification via a mobile app where their photo and passport data are uploaded.^[22]

There is no available information relating to grievance redressal in case of misuse or disputes relating to electronic documents/signatures or digital ID. The Agency for Innovation and Digital Technologies is tasked with managing e-government, regulating the provision of digital public services, circulation of electronic documents and use of electronic signatures.^[23] Its mandate includes oversight of the unified contact centre for public services and public service centers, which indicates that citizens may submit service-related complaints through this channel.^[24]

Data Protection

Tajikistan has a dedicated Law of the Republic of Tajikistan On Personal Data (2018) (‘Personal Data Law’).^[25] The law sets general rules for collection, processing, storage and protection of personal data, and designates a state body for personal data protection and information security.^[26] The Personal Data Law requires that personal data be collected and processed on a lawful basis, for specified purposes, and that measures be taken to prevent unauthorized leakage, copying, theft, alteration, disclosure or destruction.^[27] The Personal Data Law requires operators to take ‘measures’ to protect personal data from unauthorized access, leakage, copying, theft, loss, alteration, disclosure or destruction.​^[28] Based on publicly available information, there is no explicit requirement that personal data, including Digital ID data, must be encrypted or that particular cryptographic standards be used.^[29]

There is limited information available on the breach of privacy and issues of surveillance in the country in relation to ID systems. It should be noted that the new ‘Face ID’ based digital registration of pensioners requires uploading facial images and passport data into a central system via mobile devices, enabling potential cross-checking against other databases or CCTV without any visible independent oversight regime.^[30] The lack of legal constraints on government access to identity data creates structural risks of function creep (a gradual increase in using the system beyond the purpose for which it was originally intended), profiling, and unchecked monitoring. Regional digital rights observers warn against increasing adoption of facial recognition and integrated identity systems without adequate privacy impact assessments or public debate.^[31]

International Commitments

There is no evidence that Tajikistan is party to any multilateral treaty whose primary subject matter is ‘digital identification’ or ‘e-ID’. Tajikistan is also not subject to the EU GDPR or any EU adequacy regime, and there is no evidence of membership in OECD data-protection treaty frameworks. Tajikistan has not ratified the 1954 or 1961 Statelessness Conventions. However, its Constitutional Law on the Legal Status of Foreign Citizens and Stateless Persons and the Amnesty Law (2019) create domestic mechanisms for regularization and documentation of stateless persons.^[32]

As a signatory, the country is obliged to ensure birth registration (ICCPR Article 24(2); and CRC Article 7), non-discrimination (ICCPR Article 2, 26; ICESCR Article 26; and CRC Article 2), and access to essential services like health (ICESCR Article 12), education (ICESCR Article 13), and social security (ICESCR Article 9).^[33] Furthermore, in its General Comment No. 25, the CRC Committee states that digital systems should be created such that they enable all children to safely access essential digital public services and educational services without discrimination.^[34]

Moreover, in the 2024 the CEDAW Committee’s concluding observations (seventh periodic report), explicitly recommended ensuring that stateless women, women of undetermined nationality and women at risk of statelessness and their children have adequate access to identity documents, justice, employment, health care, housing and social protection.^[35]