This article outlines a phased, EU-integrated path toward the recognition of blockchain records in Ukraine.

A realistic path toward recognizing blockchain records as legally valid evidence in Ukraine lies in a gradual, hybrid approach. This approach combines regulatory flexibility with the harmonization of national legislation with European standards, in particular the requirements of the MiCA Regulation.

The Law of Ukraine “On Virtual Assets” No. 2074-IX, adopted in 2022, has not yet entered into force due to the lack of amendments to the Tax Code of Ukraine. A key step forward was Draft Law No. 10225-d, which passed its first reading in September 2025. It proposes a new version of the law—“On Virtual Asset Markets”—introduces a clear model for taxing virtual assets effective January 1, 2026, and provides for specific amendments to procedural legislation, particularly the Criminal Procedure Code of Ukraine.

These changes are expected to allow entries in qualified distributed ledger systems (DLT/blockchain) to be recognized as electronic evidence in criminal proceedings. In addition, they will simplify the mechanisms for seizing, freezing, and specially confiscating virtual assets in cases involving fraud, money laundering, or corruption offenses.

Phased Implementation of Legal Recognition of Blockchain Records

2025 — launch and expansion of regulatory sandboxes: the NBU’s sandbox for fintech, and the Innovation Sandbox of the Ministry of Digital Transformation and the Ukrainian Startup Fund for AI and blockchain solutions (until October 2026, with a possible extension). In a pilot phase, blockchain records in limited areas (tokenization of property rights, intellectual property, and state registries) will be presumed authentic under regulatory oversight.

At the same time, targeted amendments will be made to the Code of Civil Procedure, the Code of Commercial Procedure, the Code of Criminal Procedure, and the Code of Administrative Procedure: expanding the list of electronic evidence to include records from qualified DLT systems, as well as establishing rules regarding access to data for the purposes of investigating and confiscating virtual assets.

2026–2028 — following the entry into force of the comprehensive law (expected in late 2025–early 2026) the presumption of authenticity of qualified blockchain records will be established across all sectors, integrated with Diia as a state oracle, and gradually extended to civil, commercial, and criminal legal relationships.

This approach—from a “sandbox” presumption to full recognition—allows for avoiding radical changes to the Civil Code of Ukraine, ensures legal certainty, and aligns with best international practices (in particular, the EU’s DLT Pilot Regime, as well as the approaches adopted in the state of Wyoming, USA). With sufficient political will and the completion of the legislative process for Bill No. 10225-d, Ukraine could become a regional leader in the legal recognition of blockchain technologies as early as 2028.

Integration with registries through pilot projects

The Blockchain Estate Registry (BER) initiative, developed by the NGO “Virtual Assets of Ukraine” in collaboration with the Blockchain4Ukraine parliamentary group and the Ministry of Digital Transformation of Ukraine, is testing the transition from traditional registries (in particular, the State Registry of Real Rights to Real Estate) to blockchain systems. Entries in such systems become legally binding after notarization using a qualified electronic signature (QES) that complies with the requirements of the EU’s eIDAS Regulation. Pilot projects already cover land and property rights, with plans for further expansion in 2026–2027.

Lobbying and Advisory Support

The Ministry of Digital Transformation of Ukraine, in collaboration with Blockchain4Ukraine, is advancing relevant legislative initiatives through public consultations, tenders for operators, and the implementation of sandbox models for virtual assets by October 2026. The goal of these measures is to fully integrate the Ukrainian virtual asset market into the European legal framework by 2027.

This path is realistic given the existing experience in implementing digital government services, particularly the Diia platform; however, it also requires overcoming tax and regulatory barriers. Provided there is sustained political will, Ukraine has the potential to become a leader in blockchain regulation in the region, maintaining a balance between innovation and legal certainty.

Stakeholders Who Should Be Involved in the Process

To effectively recognize blockchain records as legally binding in Ukraine, it is essential to engage a diverse range of stakeholders who will ensure a balance of interests, compliance with international standards, and practical implementation. This will help avoid mistakes similar to those that have occurred in overregulated countries and accelerate integration with Diia and state registries.

Key stakeholders include:

• Government agencies: the Ministry of Digital Transformation (MDT) and the Ministry of Justice—to coordinate pilot projects; regulators, such as the NBU (Regulatory Sandbox for blockchain-based fintech) and the NSSMC — to oversee virtual assets; legislators from the Verkhovna Rada (Committee on Digital Transformation)—to amend Laws No. 2074-IX and No. 10225-d.

• The business sector: startups, crypto exchanges, and developers (e.g., the NGO Virtual Assets of Ukraine); associations such as the Blockchain Association of Ukraine—to provide expertise and lobby to avoid barriers to innovation; private registry operators—to test solutions.

• Judicial branch: the Supreme Court and specialized courts (anti-corruption, commercial)—to establish case law recognizing blockchain evidence, particularly in cases involving virtual assets or AML.

• International partners: the EU—for harmonization with MiCA (expected by 2027); GFIN (the NBU has been a member since 2019)—for fintech cooperation; FATF and the UN—for AML/CFT standards; donors such as the Eurasia Foundation or UK Aid—to fund pilot projects, such as BER.

It is also important to engage the academic community (the National Academy of Legal Sciences of Ukraine, universities such as Kyiv National University and Kyiv Polytechnic Institute) for research on risks, such as the 51% attack, and civil society (NGOs such as Transparency International) to monitor anti-corruption aspects and gather feedback from users and investors.

Engagement through working groups, consultations, and memorandums (as in the BER or Diia.City projects) will ensure a comprehensive and inclusive approach with the potential to finalize key legislative and regulatory changes by 2028.

How to Avoid the Risks of Overregulation

A balance between minimizing the risks of abuse and preserving room for innovation in the regulation of blockchain technologies and virtual assets is achieved through the application of flexible, risk-based approaches that simultaneously protect the public interest without hindering technological development.

Risks associated with fraud, money laundering, terrorist financing, or the loss of investor assets are mitigated through mandatory compliance with AML/KYC standards, continuous monitoring of transactions in accordance with the FATF’s recommendations for virtual assets, mechanisms for the confiscation and freezing of assets in criminal proceedings, and the use of modern technologies for the automated detection of suspicious transactions. In addition, there is a gradual transition to energy-efficient consensus mechanisms, such as Proof-of-Stake, which significantly reduces the technology’s environmental impact.

At the same time, innovation is guided by the principle of “same activity—same risks—same regulatory consequences,” which underpins MiCA in the European Union. Regulation is being adapted to specific asset types and use cases—from stablecoins and DeFi to tokenized assets and NFTs. The industry is given the opportunity to independently develop and adhere to codes of conduct and best practices, as well as actively apply compliance technologies (RegTech) that enable compliance with requirements without an excessive administrative burden.

The main tools for achieving this balance are regulatory sandboxes, which allow new solutions to be tested under regulatory supervision without full regulatory pressure in the early stages; international coordination within IOSCO, FATF, and GFIN to harmonize approaches and avoid regulatory arbitrage, as well as regular review of the regulatory framework to account for new technological risks and opportunities. It is precisely this approach—as demonstrated by the EU (MiCA and the DLT Pilot Regime), Ukraine (the NBU sandbox and the Ministry of Digital Transformation’s Innovation Sandbox), and certain jurisdictions such as the United Kingdom or Singapore, ensures a high level of protection without hindering the development of distributed ledger technologies.

Potential for Regulatory Sandboxes

The potential for pilot regulatory regimes (regulatory sandboxes) in the field of digital recording of intellectual property (IP) in Ukraine is significant and is already being implemented in practice.

In June 2025, the Ministry of Digital Transformation of Ukraine, together with the Ukrainian Startup Fund, launched Innovation Sandbox—a pilot program for startups in the fields of artificial intelligence (AI) and blockchain technologies. This sandbox operates as an experimental space through October 2026 (with the possibility of extension and formalization into a permanent tool), where companies receive free product audits, individual consultations, and recommendations on legal, business, and technical aspects.

Particularly relevant for IP, the program includes a comprehensive intellectual property analysis—an assessment of patentability, a rights protection strategy, implementation of Privacy by Design and Privacy by Default, as well as recommendations for managing IP assets to scale into international markets. This is ideal for testing IP tokenization, for example, through NFTs to secure rights to creative content, patents, inventions, or digital assets, with government oversight and without the full regulatory burden in the early stages.

This approach is similar to the successful BER (Blockchain Estate Registry) pilots for real estate, where blockchain records become legally binding after notarization. In the field of intellectual property, the sandbox allows for safe experimentation with tokenization in the healthcare, education, agriculture, defense, and digital economy sectors—precisely where innovations require reliable protection of rights.

This complies with European standards (EU AI Act, MiCA) and helps shape future regulations based on real-world cases, accelerating innovation without compromising legal certainty. If the program proves effective, it could serve as the foundation for a specialized sandbox dedicated to digital IP, transforming Ukraine into a regional hub for blockchain-based protection of intellectual assets.