Patenting in Georgia, Kazakhstan, Uzbekistan and Ukraine – what international applicants need to know

We look at common features, key risks and recent updates shaping patent protection across these four Eurasian countries.

Georgia, Kazakhstan, Uzbekistan and Ukraine form an evolving IP region where international applicants file a sizeable share of patents. Each country has a well-functioning system and offers clear routes to protection.

“Our clients are very interested in these countries, where we’ve built strong local practices over more than 20 years. We have extensive regional experience and direct connections with trusted local agents,” says Aleksandr Belotcerkovskii, European Patent Attorney and Head of Local Agent Network at Papula-Nevinpat.

“We always recommend using a professional local attorney,” he says. “There are so many small but critical differences – from power-of-attorney formats to the way examiners interpret office actions. You need local knowledge in these countries.”

Key similarities and differences

All four countries accept applications for both inventions and utility models. An original power of attorney is always required. Fees are generally low but may rise if an application has many claims to be examined.

Applications must be translated into the local language, typically within two months of filing. Russian can be used in Kazakhstan and Uzbekistan, but not in Ukraine or Georgia.

“The prosecution process in the region usually follows the familiar pattern: formal and substantive examination leading to grant or rejection. While patentable subject matter varies between the countries, all require novelty, inventiveness, industrial applicability and unity of invention,” explains Belotcerkovskii.

“I always recommend highlighting the technical effects of the invention in the main claim and any key dependent claims. This is important given how the inventive step is assessed in these countries,” he says.

Ukraine, Uzbekistan, and Kazakhstan require local inventions to first be filed in-country, so the patent office can alert the appropriate authority to check for state secrets. The rule is applied differently in Georgia, as explained below.

Georgia

The country is party to the PCT, the Paris Convention, the Budapest Treaty and TRIPS. This means that Georgia is a member of both WIPO and the WTO. It is not part of the Eurasian Patent Convention, but it became a European Patent Office (EPO) validation state in January 2024.

Around 230 patent applications were filed in Georgia in 2023. Roughly 60% of these came from foreign applicants – mainly from the United States.

Georgia has no first filing requirement in its patent law, but the Ministry of Defence requires that if an invention relates to military technology and originates from a Georgian citizen, it must be filed first in Georgia.

Prosecution typically takes two to three years, with Georgian examiners leaning towards the EPO’s problem-solution approach when assessing the inventive step.

“Georgian examiners are often quite flexible – they may even admit they’re not experts in the field and leave it up to the applicant to decide whether to amend an application or not,” says Belotcerkovskii.

Post-grant amendments can only be made via re-examination. Applicants cannot change the patent in any way once it’s been granted.

“You should also be aware of Georgia’s strict rules on divisional applications,” he says. “Once an acceptance is issued, it’s too late to file a divisional. This is why we recommend doing so early, ideally when requesting examination.”

Invalidation happens through a request to the patent office for re-examination. The next instance is to appeal to a civil or criminal court, although this is rare. Infringement cases, however, must always go through the courts in Georgia.

Kazakhstan

Kazakhstan is party to the PCT, the Paris Convention, the Budapest Treaty and TRIPS, and is also a member of the Eurasian Patent Convention.

More than 1,100 patent applications were filed in 2024, with around 25% coming from foreign applicants. An additional 1,600 utility model applications were filed, mostly by local applicants. The country has a mature patent system, with prosecution typically completed within two and a half years.

Kazakhstan assesses the inventive step according to the ‘technical effect’ approach. Arguments typically used in EPO responses – such as ‘teaching away’ or non-obviousness based on combining prior art – carry little weight under this approach.

“What matters in Kazakhstan is showing that the distinguishing features of your invention provide a technical effect that isn’t already known in the prior art,” explains Belotcerkovskii.

Kazakhstan is the only country among the four where applicants can request acceleration. Requests may even be free in key areas like renewable energy, ICT technology and infectious disease control.

Post-grant amendments are not allowed in Kazakhstan. The only way to amend a granted patent is to remove an entire group of claims.

Uzbekistan

Uzbekistan is party to WIPO, the Paris Convention and the Budapest Treaty. It is not yet a member of the WTO but is expected to join in 2026. The country is not part of the Eurasian Patent Convention either.

In 2023, around 750 patent applications were filed locally, with foreign applicants accounting for approximately 30%.

“In our experience, prosecution in Uzbekistan generally takes two to three years,” says Belotcerkovskii. “Delays can occur, but once the actual examination starts, it usually moves quickly.”

“A recent change in Uzbekistan is the significant reduction of official fees for foreign applicants, who were previously paying the patent office up to EUR 1,500 just to file. These fees have now been aligned with domestic levels – in some cases dropping by 80%,” he says.

In Uzbekistan, inventive step is also assessed according to the ‘technical effect’ approach. While procedures for post-grant amendments are unestablished, divisional applications must be filed before a patent is granted or the appeal period expires following a rejection. Infringement and invalidation actions can be brought either before the Ministry of Justice or the court.

Ukraine

The country is party to the PCT, the Paris Convention, the Budapest Treaty and TRIPS. It is not a member of the Eurasian Patent Convention.

“The number of filings in Ukraine had been declining in recent years, but now it has stabilized. Our estimation for 2024 is about 3,000 filings. This is roughly the same level as 2023,” says Belotcerkovskii.

“Despite the hardships in Ukraine, we haven’t seen major delays from the patent office. Prosecution usually takes two to three years. The patent office is still issuing office actions and even recently updated the country’s patent law,” says Belotcerkovskii.

An important recent change is canceling the ‘wartime freeze’ of deadlines. As of April 2025, Ukraine is reintroducing normal due dates with a grace period. Ukraine has also published long-awaited patent regulations to accompany its updated patent law. These clarify many key issues, including use-claims.

Ukraine also assesses the inventive step under the ‘technical effect’ approach. Post-grant amendments are only possible based on dependent claims, which makes claim strategy during filing especially important.

“If you expect challenges, include as many useful dependent claims as possible in your original filing,” Belotcerkovskii advises.

In Ukraine, infringement cases go directly to court, with the possibility of appeal. Invalidation is handled by an appeals chamber within the patent office.

You can watch the webinar on this topic by clicking here.