· Gökçen Özkan
MLETR Adoption Map — Who Has Enacted It, and How Far
Short answer. As of 14 October 2026, UNCITRAL lists 13 states that have enacted legislation based on or influenced by MLETR, including the United Kingdom, Singapore, France, China and the Marshall Islands. Scope varies: China covers only bills of lading, Mauritius only bills of exchange. Japan has a bill in preparation. Türkiye is not on the list.
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. UNCITRAL lists it as influenced by the Model Law rather than a direct enactment.
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; influenced by the Model Law (UNCITRAL note). Revised Maritime Code in force since 1 May 2026.
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. Influenced by the Model Law (UNCITRAL note).
In preparation
Japan. Legislative Council approved the eBL reform outline on 9 September 2024 (control replaces possession); a Commercial Code bill was reported in late September 2026 as planned for the autumn extraordinary Diet session. Not yet enacted.
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 recognises electronic possession of an eBL and defines exclusive control per MLETR Arts. 10–11, building on TCC Art. 1526(2), which already allows a bill of lading to be signed electronically.
Sources: UNCITRAL MLETR adoption status; UK ETDA 2023; France Décret 2025-811. UNCITRAL notes the list reflects only enactments made known to its Secretariat. Status list re-checked on 14 October 2026: 13 States, no change.
