· Gokcen OZKAN
MLETR Adoption Map — Who Has Enacted It, and How Far
MLETR is a model, not binding law — each jurisdiction must enact it, and the scope differs sharply. Some cover all transferable records; some only bills of lading; some only bills of exchange. This map tracks who has done what, with the source for each. Türkiye is not yet on it — see our Türkiye eBL Legal Status Tracker.
Enacted (notified to UNCITRAL)
United Kingdom — 2023. Broad (all trade documents). Electronic Trade Documents Act; common-law drafting; governs most charterparties.
France — 2024. Broad, full transposition. First EU member to fully transpose; Law 2024-537 + Decree 2025-811; civil-law model.
Singapore — 2021. Broad. Early adopter; regional trade hub.
China — 2025. Narrow — bills of lading only.
Mauritius — 2025. Narrow — bills of exchange only; does not cover bills of lading.
UAE — Abu Dhabi Global Market — 2021. Broad within ADGM; financial free-zone jurisdiction.
Bahrain — 2018. Broad; among the earliest adopters.
Belize — 2021. Broad.
Paraguay — 2021. Broad.
Kiribati — 2021. Broad.
Papua New Guinea — 2022. Broad.
Timor-Leste — 2024. Broad.
Marshall Islands — 2025. Broad; a major flag state — relevant to shipping registries.
In preparation
Japan. Commercial Code amendment expected; implementation around FY2026, eBL-focused.
Türkiye. Not enacted. EBRD–Ministry of Trade reform in progress — see our tracker.
Why scope matters — the strategic reading for Türkiye
Two lessons. First, scope is a choice: China legislated for bills of lading only, Mauritius for bills of exchange only — a narrow eBL-first law is a legitimate, faster path. Second, legal family matters: the UK’s open-textured common-law approach fits Türkiye’s civil-law tradition less well than France’s prescriptive codification (Decree 2025-811). If Türkiye follows the French route, expect a detailed statute that removes the Law No. 5070 Art. 5(2) exception for eBLs and defines exclusive control per MLETR Arts. 10–11.
Sources: UNCITRAL MLETR adoption status; UK ETDA 2023; France Décret 2025-811. UNCITRAL notes the list reflects only enactments made known to its Secretariat.
