A revised labor management document for the Roghun Hydropower Plant (HPP) sets out updated requirements for workers’ accommodation, occupational safety, complaints procedures and compensation for workplace accidents. However, it also acknowledges that problems with wages, working conditions and transport remain.
The updated document, dated September 2026, was published on the official website of OJSC NBO Roghun. It was prepared in accordance with Tajikistan’s legislation and the World Bank’s Environmental and Social Standard ESS2, which covers labor relations and working conditions.
As of August 2026, 20,563 people were employed at the construction site, up approximately 38% from 14,877 at the end of 2023.
Asia-Plus compared the updated document with the previous version, published in February 2024, to identify what has changed and which problems remain unresolved.
What violations were identified, and what has changed?
The February 2024 document described violations identified during an inspection of the construction site in March 2023.
Some contractors’ employment contracts lacked complete information on wages, working hours, breaks and rest periods. Inspectors also reported delayed wage payments and cases in which workers on 12-hour shifts were required to work overtime.
Other shortcomings involved the provision of personal protective equipment, lighting in certain construction areas and the safety of equipment. The 2024 document called for these problems to be addressed.
The September 2026 version states that requirements governing employment contracts and wage payments have been established and are now in force across the project.
Contractors must provide workers with contracts specifying wages, working hours, rest periods, annual leave and sick leave. Employment terms must be written in a language workers understand, preferably Tajik.

Employers must pay wages in full and on time. Overtime is prohibited for workers on 12-hour shifts.
Although these requirements were already included in the previous document, the 2024 version described them as measures to be introduced, while the updated version presents them as established rules.
However, the new document does not confirm that all violations have been eliminated. It acknowledges that incomplete employment contracts, excessive overtime and delayed wages have occurred during the project’s implementation. It does not specify how many recent violations were identified or which contractors were responsible.
Work schedules to be reviewed
The updated document also addresses the organization of shift work.
A significant proportion of construction workers work 12-hour shifts, alternating between day and night duty on a 15-day rotation. According to the document, these schedules need to be reviewed for compliance with Tajikistan’s Labor Code.
The working-time limits cited in the document are 40 hours per week under standard conditions and 35 hours for hazardous, harmful, heavy and underground work.
Project management and contractors must review existing schedules, rest periods and measures to prevent fatigue.
Shorter daily shifts are being considered as a possible solution, but the document does not set out a final decision to change the current arrangements.
Workers’ accommodation requirements clarified
The new version provides more detailed requirements for workers’ living conditions.
Where national legislation does not impose stricter standards, sleeping areas must provide 4–5.5 square meters per person, with a ceiling height of at least 2.1 meters.
Each worker must have a separate bed, a clean mattress, bedding and storage space for personal belongings. Workers on day and night shifts may no longer share the same bed, although employees working different 15-day rotations may use the same sleeping space at different times.

The document also specifies requirements for ventilation, heating, lighting, toilets, showers, drinking water and fire safety.
Separate provisions cover accommodation for women, including separate sanitary facilities, adequate lighting and privacy.
Despite these requirements, the document acknowledges that some workers continue to live in unsatisfactory conditions.
As of mid-2026, contractors providing substandard accommodation were still upgrading their facilities. Some older dormitories are being replaced with new buildings because of rising water levels in the reservoir.
Digital platform introduced for workers’ complaints
The February 2024 document noted that there was no unified grievance mechanism accessible to all construction workers.
According to the updated version, such a mechanism has now been established, alongside a digital feedback platform through which workers can submit complaints.
The system allows complaints to be registered, assigned to responsible personnel, tracked during processing and monitored if they remain unresolved.
Workers can also submit complaints in person, by telephone, email, WhatsApp or SMS, or through dedicated complaint boxes. Anonymous submissions are permitted.
However, the document acknowledges that complaints previously submitted through informal channels were not always properly registered or tracked.
It says the recording and monitoring of complaints must be strengthened. Contractors are responsible for addressing complaints at the initial stage, while project management and Bureau Veritas oversee the process.
Bureau Veritas takes over safety supervision
Since July 1, 2026, international company Bureau Veritas has been responsible for monitoring contractors’ compliance with occupational health and safety and environmental requirements.
Previously, these responsibilities fell under the general construction supervision system operated by the employer’s representative.
Bureau Veritas now separately monitors safety compliance among contractors and subcontractors, as well as workers’ accommodation and grievance mechanisms.
According to the document, contractors have developed occupational health and safety plans that must be reviewed regularly.
The requirements include mandatory safety briefings, daily equipment inspections, free personal protective equipment for workers and the recording of workplace incidents.
Workers must also undergo medical examinations before starting work, annually during employment and when their employment ends.

What compensation are workers entitled to after accidents?
The updated document contains a more detailed section on compensation for workplace injuries, disability and fatalities.
Under the provisions of Tajikistan’s Labor Code cited in the document, a worker who becomes disabled because of a workplace accident is entitled to a lump-sum payment of at least 12 times their average monthly wage.
If a worker dies, their dependants are entitled to a lump-sum payment of at least 60 times the deceased worker’s average monthly wage.
The legislation also provides for compensation for lost earnings, injury-related expenses and moral damages in cases established by law. These are not new legal provisions; the 2026 document explains them in greater detail.
Asia-Plus previously reported the deaths of three workers at the Roghun HPP construction site.
In January 2025, Sanat Rahim, head of the State Industrial Safety Inspectorate, said an inspection had identified safety violations during work on the plant’s fifth generating unit. According to him, a criminal case was opened against those responsible, and the technical investigation materials were referred to the Roghun prosecutor’s office.
Transport problems remain
The updated document acknowledges that the construction site still lacks a unified, centralized system for transporting workers around the facility.
Some contractors provide transport, but workers often have to walk to their workplaces or travel in passing vehicles.
Transport home after completing a 15-day shift is also not always guaranteed, despite employers’ commitments.
The document says the transport system needs further improvement. More than 2,000 vehicles and pieces of mobile equipment use the project’s roads every day, requiring additional safety measures.

Dam completion now estimated for 2032
The revised document also changes the projected completion date for the Roghun HPP dam.
The February 2024 version estimated that the dam would be completed around 2029. The September 2026 version gives 2032 instead.
The estimated total project cost recorded in the documentation has also increased from $4.9 billion to $6.6 billion. These figures refer to projected project costs, not the amount of funding still required.
Asia-Plus previously reported that, according to an assessment by international ratings agency S&P Global Ratings, approximately $5.8 billion in additional funding would be needed to complete the entire project, with completion expected by 2035.
The completion of the dam and the completion of the entire hydropower complex are separate milestones.
About the Roghun HPP
The Roghun HPP is being built on the Vakhsh River, approximately 110 kilometers from Dushanbe. Once completed, it is expected to have an installed capacity of 3,780 MW, with six generating units rated at 630 MW each and annual electricity production of approximately 14.4 billion kWh.
Two generating units were commissioned in 2018 and 2019 and are operating at reduced capacity.
The dam is designed to reach a height of 335 meters. According to the latest official data cited in the document, it has reached 190 meters, while the volume of material placed exceeds 61% of the planned total.
Since 2008, a total of 60.3 billion somoni from the state budget and other sources has been allocated to the construction of the Roghun HPP.
The updated project document estimates that dam construction will be completed around 2032, while the reservoir is expected to reach its design water level around 2036.
