Thirteen jurisdictions have legislated on the UNCITRAL model law for electronic trade documents, 12 since 2021
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Ossiano Guides · Digital trade
A UN model law lets an electronic record do the legal job of a paper bill of lading or bill of exchange. National laws, ICC rules and US commercial law are putting it into practice at different speeds.
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01 · The model law
MLETR lets control of an electronic record count as holding the paper
Some trade papers carry a legal claim. A stands for the goods on a ship. A is a signed order to pay money. The person who holds the paper can claim what it promises. The law calls these papers . Bills of lading, bills of exchange, and are all examples, per UNCITRAL.
UNCITRAL is the United Nations commission on international trade law. On July 13, 2017, it adopted the Model Law on Electronic Transferable Records, or , per UNCITRAL. A model law is a template. Each country passes its own law to use it. MLETR aims to let electronic versions of these papers be used legally at home and across borders.
A computer file can be copied, so nobody holds it the way they hold a sheet of paper. MLETR solves this with one idea: . When one identified person has exclusive control of the electronic record, the law treats that like holding the paper. UNCITRAL calls control "a fundamental notion of the Model Law".
The model law rests on three principles, per UNCITRAL. First, electronic means get equal treatment with paper. Second, : an electronic record can do the legal job of paper when reliable methods identify it, keep it under control and keep it whole. Third, : the law works with any suitable technology and picks none.
Our guide to electronic bills of lading shows how this works for one document, with adoption data from shipping. This guide covers the law itself.
02 · Adoption
Thirteen jurisdictions have passed laws based on MLETR, five of them in 2021
UNCITRAL keeps a table of who has enacted the model law. It lists 13 jurisdictions with laws based on or influenced by MLETR, per the UNCITRAL status page. A jurisdiction is a place with its own body of law. Twelve on the list are countries. The thirteenth is Abu Dhabi Global Market, in the United Arab Emirates.
Bahrain came first, in 2018. Five followed in 2021: Abu Dhabi Global Market, Belize, Kiribati, Paraguay and Singapore. Papua New Guinea came in 2022 and the United Kingdom in 2023. France and Timor Leste followed in 2024. China, the Marshall Islands and Mauritius joined in 2025. That makes 12 of the 13 dated 2021 or later, by our count from the UNCITRAL table.
The year is the one UNCITRAL shows. For some places it is the year the law passed. For others it may be the year the law took effect. Paraguay is an example. UNCITRAL lists it under 2021, and its Ley No. 6822/21 came into force on May 1, 2022, per Paraguay's judiciary.
We opened the national texts where we could. Bahrain issued Decree-Law No. 55 of 2018 on electronic transferable records. In Singapore, Parliament passed a bill on February 1, 2021 to amend the Electronic Transactions Act to adopt MLETR, per the Ministry of Digital Development and Information. France passed Law No. 2024-537 of June 13, 2024. Decree No. 2025-811 of August 12, 2025 puts it into effect. Figure 1 links every law we found.
Figure 1 · Interactive
Where MLETR-based law is on the books
Filter by basis or search for a place. Each law name links to its text. Rows marked "not confirmed" await the national text.
Source: UNCITRAL, status of the Model Law on Electronic Transferable Records (2017), accessed September 30, 2026. Instrument names from each jurisdiction's official text.
Figure 2 · Interactive
Cumulative MLETR enactments, 2018 to 2025
Tap or hover on a year to see new laws and the running total. The table below names who enacted each year.
Source: UNCITRAL, MLETR status table, accessed September 30, 2026. Cumulative counts calculated by our Research Desk.
03 · Scope limits
Three of the laws are influenced by MLETR, and two cover only one document
Some laws follow the model law's text closely. Others take its ideas and use their own words. UNCITRAL marks three laws as "influenced by the Model Law and the principles on which it is based". They are China, the Marshall Islands and the United Kingdom, per the UNCITRAL status page.
Two laws cover a single kind of document. Mauritius covers bills of exchange only. Its Act No. 18 of 2025 adds a new Part IA, Electronic Bills of Exchange, to its Bills of Exchange Act. China covers bills of lading only. Its revised Maritime Code (2025) deals with the in Articles 82 to 86. That is the Code's name for a transport document in electronic form. We read an English translation hosted by the Nanjing Maritime Court.
So a law on the list may not cover every document you trade with. Check its scope first. Our guides to bills of exchange and promissory notes and the bill of lading explain the paper versions.
04 · The UK Act
The UK Act names eight trade documents that can now be electronic
The UK received royal assent on July 20, 2023, per legislation.gov.uk. Royal assent is the last step that turns a UK bill into law. The Act came into force on September 20, 2023, per legislation.gov.uk.
The Act starts with a test. Under section 1(1), a is one whose possession is needed, by law or commercial custom, to claim what it promises, per section 1 of the Act. Section 1(2) then lists eight examples:
- bill of exchange
- promissory note
- bill of lading
- ship's delivery order
- warehouse receipt
- mate's receipt
- marine insurance policy
- cargo insurance certificate
An gets the same legal effect as paper when a manages it, under section 2 of the enacted text. In plain terms, the law looks at the system that holds the record, not just the file. Our trade documents checklist shows where each of these documents fits in a trade.
05 · The US route
In the US, the route runs through a new Article 12 of the Uniform Commercial Code
The US takes a different route from the countries on the UNCITRAL list. Its business law sits in the Uniform Commercial Code, or UCC. The UCC is a set of model rules that each US state adopts as its own law.
In 2022, the American Law Institute and the Uniform Law Commission approved amendments to the UCC, including a new Article 12, per the American Law Institute. The amendments update the rules for deals that involve virtual currencies and distributed ledger technologies, per the Uniform Law Commission. A distributed ledger is a shared record kept in step across many computers. Article 12 sets rules for what it calls a .
Each state passes the amendments on its own timetable. We have not yet verified a count of states that have done so. Check the law of the state that governs your contract.
06 · Bank rules
ICC rules let banks take electronic records under letters of credit and collections
Banks follow rules from the International Chamber of Commerce (ICC) as well as national law. The ICC wrote electronic rules early. The first eUCP, a 12-article supplement to UCP 500 for electronic presentation, came into force in April 2002, per the ICC. UCP 500 was the version of the letter of credit rules in use at the time.
A is a bank's promise to pay the seller against the right documents. Letters of credit incorporate , the ICC rules for documentary credits. The is a supplement and digital companion to UCP 600, per the ICC. It allows an to be presented, alone or with paper documents. The current text is Version 2.1, ICC Publication No. 823E, per the eUCP rules. The ICC says Version 2.1 aligns the eUCP with MLETR, per the ICC Digital Library.
Collections have a matching supplement. In a , banks pass the shipping documents to the buyer against payment or a promise to pay. The , Version 1.1, supplements , the ICC rules for collections. See the eURC rules text and the ICC page on eURC.
The ICC also has rules for whole trade deals done with electronic records. The came into force on October 1, 2021, per the ICC. Our guides to letters of credit and documentary collections explain the paper rules.
Figure 3
The digital trade rulebook, 2002 to 2023
Each row is one rule or law with its date as stated by the issuing body.
Sources: International Chamber of Commerce; UNCITRAL; American Law Institute; legislation.gov.uk. Dates as stated by each issuing body.
07 · Ossiano view
Digital trade law is converging on one idea: control
OBSERVATION 01
A common legal test
MLETR treats exclusive control of a record like holding the paper. Every law on the UNCITRAL list is based on the model law or influenced by it. A shared test helps parties in different countries recognize the same record.
OBSERVATION 02
Adoption has sped up
Twelve of the 13 listed laws are dated 2021 or later, by our count from the UNCITRAL table. France, China, the Marshall Islands and Mauritius joined in 2024 and 2025.
OBSERVATION 03
Bank rules were ready early
The ICC aligned eUCP Version 2.1 with MLETR, and the URDTT have been in force since October 1, 2021. Banks taking electronic records under a credit already have a rulebook to cite.
Summary
Thirteen jurisdictions let control of an electronic record stand in for the paper, and bank rules already match
MLETR is a UN model law adopted on July 13, 2017. It lets an electronic record do the legal job of a paper bill of lading, bill of exchange or similar document. The key idea is control: one identified person with exclusive control of the record is treated like the holder of the paper.
Thirteen jurisdictions have laws based on or influenced by it, and 12 of them are dated 2021 or later. Some cover only one document: Mauritius covers bills of exchange and China covers bills of lading. The UK Act, in force since September 20, 2023, names eight trade documents. The US uses a new Article 12 of the UCC. ICC rules (eUCP 2.1, eURC 1.1 and URDTT) let banks work with electronic records.
This guide is general reference. Laws differ by place and change over time. Take legal advice on which law governs your documents before you rely on an electronic version.
Related guides: electronic bills of lading, bills of exchange and promissory notes, the bill of lading, the trade documents checklist, title and ownership in commodity trade and letters of credit. Instrument cards: letter of credit (sight), documentary collection, documents against payment (D/P), bill of exchange and promissory note, forfaiting and warehouse finance (warehouse receipts). Every term is defined in the Trade Finance Glossary.
For questions on how these laws affect existing or planned trade finance exposures, contact the Ossiano Research Desk.
Sources
- UNCITRAL, Status: UNCITRAL Model Law on Electronic Transferable Records, undated; accessed September 30, 2026. Supports: 13 jurisdictions with legislation based on or influenced by the Model Law; years in the status table; footnotes on influenced laws, Mauritius (bills of exchange only) and China (bills of lading only); Figures 1 and 2.
- UNCITRAL, UNCITRAL Model Law on Electronic Transferable Records (2017), 2017. Supports: adoption on July 13, 2017; purpose; scope; control as the equivalent of possession; the three principles; Figure 3.
- legislation.gov.uk, Electronic Trade Documents Act 2023, 2023. Supports: in force on September 20, 2023; Figure 3.
- legislation.gov.uk, Electronic Trade Documents Act 2023, section 1, 2023. Supports: the paper trade document test in section 1(1); eight example trade documents in section 1(2).
- legislation.gov.uk, Electronic Trade Documents Act 2023, enacted text, July 20, 2023. Supports: royal assent on July 20, 2023; electronic trade document and reliable system (section 2); Figure 1.
- Ministry of Legal Affairs, Kingdom of Bahrain, Decree-Law No. (55) of 2018 with respect to electronic transferable records, 2018. Supports: Bahrain's enacting law; Figure 1.
- Ministry of Digital Development and Information, Singapore, ETA amended to facilitate transactions, provide convenience and boost trade, February 1, 2021. Supports: amendment of the Electronic Transactions Act to adopt MLETR, passed February 1, 2021; Figure 1.
- Belize Intellectual Property Office (official gazette copy), Electronic Transactions Act 2021, Act No. 25 of 2021, October 5, 2021. Supports: Belize's enacting law; Figure 1.
- PacLII (Pacific Islands Legal Information Institute), Electronic Transactions Act 2021 (Papua New Guinea), 2021. Supports: Papua New Guinea's enacting law, Part V; Figure 1.
- PacLII (Pacific Islands Legal Information Institute), Electronic Transactions Act 2021 (Kiribati), 2021. Supports: Kiribati's enacting law, Part 5; Figure 1.
- Poder Judicial, Republica del Paraguay, Entrada en vigencia de la Ley N. 6822/21, April 26, 2022. Supports: title of Ley No. 6822/21 and entry into force on May 1, 2022; Figure 1.
- Journal officiel de la Republique francaise (copy hosted by ICC France), Decret n. 2025-811 du 12 aout 2025, JORF n. 0188 du 14 aout 2025, August 14, 2025. Supports: Decree No. 2025-811 of August 12, 2025 applying Law No. 2024-537 of June 13, 2024; Figure 1.
- PacLII (Pacific Islands Legal Information Institute), Electronic Transactions Act 2025 (Republic of the Marshall Islands), 2025. Supports: the Marshall Islands' enacting law, Part VI; Figure 1.
- Financial Services Commission, Mauritius, Finance (Miscellaneous Provisions) Act 2025 (file title), 2025. Supports: Act No. 18 of 2025 adding Part IA, Electronic Bills of Exchange, to the Bills of Exchange Act; Figure 1.
- Institute of Maritime Law, Shanghai Maritime University (English translation, hosted by Nanjing Maritime Court), The Maritime Code of the People's Republic of China (Revised 2025), 2025. Supports: Articles 82 to 86 on electronic transport records; Figure 1.
- American Law Institute, Uniform Commercial Code project page, undated; accessed September 29, 2026. Supports: 2022 amendments to the UCC, including a new Article 12, approved by ALI and the Uniform Law Commission; Figure 3.
- Uniform Law Commission, Uniform Commercial Code, undated; accessed September 29, 2026. Supports: the 2022 amendments update rules for transactions involving virtual currencies and distributed ledger technologies; Figure 3.
- International Chamber of Commerce, New UCP supplement comes into force, April 3, 2002. Supports: the first eUCP, a 12-article supplement to UCP 500, in force from April 2002; Figure 3.
- International Chamber of Commerce, eUCP (ICC Publication No. 823E), 2023. Supports: current version is Version 2.1 (article e1).
- International Chamber of Commerce, eUCP version 2.1: ICC Uniform Customs and Practice for Documentary Credits, June 29, 2023. Supports: eUCP as a supplement and digital companion to UCP 600; URDTT in force from October 1, 2021; Figure 3.
- ICC Digital Library, News item on eUCP Version 2.1, July 5, 2023. Supports: eUCP Version 2.1 aligns the eUCP with MLETR; Figure 3.
- ICC Digital Library, eURC Version 1.1 rules text, undated; accessed September 29, 2026. Supports: eURC Version 1.1 supplements URC 522 (article e2).
- International Chamber of Commerce, URC 522: Supplement for Electronic Presentation (eURC), June 29, 2023. Supports: eURC Version 1.1 as the digital addition to URC 522; Figure 3.
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