COMPARATIVE ANALYSIS OF LEGAL REGULATION MODELS FOR MICROCREDIT IN DIFFERENT LEGAL SYSTEMS

Abstract

This article provides a comparative legal analysis of various legal models in the field of microcrediting and puts forward doctrinal conclusions on improving the legislation of Uzbekistan. The “microcredit regulation model” is at the center of the study. This model represents an interconnected complex of market access (licensing, proportional requirements), contractual standards, consumer protection, full credit value disclosure, price restrictions, and a system of responsible lending and supervision. The research methodology combines elements of the comparative-legal method, legal-dogmatic analysis, and institutional theory, studying legal regimes as structures that distribute risks among subjects. The role of imperative principles such as integrity and non-abuse of rights in ensuring the balance between entrepreneurial and social (financial inclusion) functions of microcredit is analyzed. Proposals have been developed for the legislation of Uzbekistan de lege ferenda (from the perspective of future legislation), which include strengthening standards for disclosing the full value of a loan, establishing rules against the coercion of tied services, introducing proportional liability lending, establishing price restrictions combined with a ban on hidden payments, standardizing contract terms, and strengthening the private legal consequences of violating information disclosure rules.