· Gokcen OZKAN
MLETR in Türkiye: Where the Law Stands, Where It Is Going
As a contract of carriage and as evidence — largely yes. As a negotiable document of title with the full legal effect of its paper equivalent — not yet. As of July 2026, Türkiye has not enacted MLETR-aligned legislation. An eBL used in Turkish trade today operates on contractual recognition among its participants, not on statutory recognition against the world. That distinction — the Sovereign Bottleneck — is exactly what the reform process now underway is designed to close.
What MLETR actually does
The UNCITRAL Model Law on Electronic Transferable Records (2017) is not self-executing; it is a template for national legislators. Its core is three articles. Article 10 sets the equivalence conditions: an electronic record qualifies if it contains the information a paper transferable document would require, and a reliable method ensures it is identifiable, controllable, and integral. Article 11 replaces possession with exclusive control. Article 12 sets the general reliability standard the system must meet. Enact those, and "holding" a bill of lading becomes something a vault-ledger can do.
Türkiye's reform: further along than the market assumes
Türkiye's MLETR adaptation is not a think-tank wish. A formal legal reform project — supported by the EBRD, applying the CASTL methodology, with a published business impact analysis for Türkiye — has moved the question from "whether" to "how." The consultation process runs through the Ministry of Trade with international partners. The window between now and enactment is precisely when reference implementations get built.
The statutory architecture that adaptation will likely require has four pieces: a general enabling provision recognizing electronic transferable records; cross-reference amendments to the Turkish Commercial Code's negotiable instruments provisions (Arts. 1228 ff. on bills of lading); repeal of the electronic-signature exclusion currently blocking negotiable instruments; and a Ministry of Trade communiqué defining reliability criteria. On the model question, the French route — Decree No. 2025-811's prescriptive civil-law drafting — fits Türkiye's institutional culture better than the UK's open-textured ETDA 2023, provided reliability criteria anchor to ICC/UNCITRAL standards so cross-border interoperability survives.
Why prepare before the law lands
The UK enacted ETDA in September 2023; the IG P&I Clubs responded by streamlining approval for systems limited to statutorily recognized eBLs. France's 2025 decree extended the civil-law path. Every jurisdiction that enacts creates the same pattern: the infrastructure ready on day one becomes the reference. Maresign's eBL environment is being engineered against MLETR Articles 10–12 and the emerging reliability criteria now — a contractual rulebook today, built to be the statutory reference implementation the day Türkiye's law enters into force.
This page states the legal position as of July 2026 and is reviewed as the reform process advances. We would rather tell you where the law actually is than where a sales deck wishes it were.
Primary sources
UNCITRAL Model Law on Electronic Transferable Records (2017) → https://uncitral.un.org/en/texts/ecommerce/modellaw/electronic_transferable_records
UNCITRAL MLETR adoption status (Türkiye is not on the list) → https://uncitral.un.org/en/texts/ecommerce/modellaw/electronic_transferable_records/status
Ministry of Trade–EBRD digital trade legal reform project → https://ticaret.gov.tr/duyurular/bakanligimiz-ve-ebrd-ortakligiyla-dijital-ticaretin-desteklenmesine-yonelik-baslatilan-projeye-iliskin-anket
DEİK — MLETR Project Phase 2 launch → https://www.deik.org.tr/duyurular-ebrd-ile-mletr-projesi-2-faz-lansman-daveti
İMEAK Chamber of Shipping — MLETR survey circular → https://www.denizticaretodasi.org.tr/tr/sirkuler/ebrd-ile-mletr-projesi--anket-sonuclari-bilgilendirme-toplantisi-hk-20823
Türkiye eBL Legal Status Tracker (our live, sourced record) → https://www.maresign.com/insights/turkiye-ebl-yasal-durum