End-to-End Trade Digitalization: Future Models

On 3 June 2025, the International and Comparative Law Research Center hosted an online discussion: End-to-End Trade Digitalization: Future Models. The event aimed to explore potential approaches to regulating international digital trade in the future.

In her opening remarks, Yulia Mullina, General Director of the ICLRC, expressed deep appreciation to all for the interest shown in the Center's study on future regulatory models for digital trade which was aimed to supplement the stock taking exercise conducted by the Secretariat of UNCITRAL. “The idea of the IСLRC research was to see how the answer to UNCITRAL texts were implemented in different jurisdictions, national legislation, including 13 jurisdictions, which are 12 countries and the European Union as a single jurisdiction”, — noted Yulia.

Anna Joubin-Bret, Secretary of UNCITRAL and Director of the International Trade Law Division in the Office of Legal Affairs of the United Nations, stressed the need for future models of digital trade: from a narrow notion of paperless trading to a broader notion of end-to-end digitalization, and the evolution of national and international approaches to its regulation. “It's all good to take stock of the past, but we do that because we want to enhance and to facilitate further use and the development of future models”, — Anna said. She emphasized the importance of good coordination between the exercises of the Secretariat and the ICLRC that will hopefully lead to a very fruitful and interesting discussion at the Commission session.

Yulia Dragunova, Head of the Legal Department's Division at the Ministry of Economic Development of the Russian Federation, promoted a step-by-step approach to the new generation of e-commerce laws. The Russian initiative, as described by Yulia, presupposes two stages of research. The first stage focuses on existing documents and their implementation practices. The second stage reflects the results of the stocktaking and analysis performed in the first stage. It offers a variety of possible approaches ranging from a new edition of existing laws to a codified convention or another type of international instrument on digital trade.

Nikolay Dmitrik, the ICLRC expert and the Head of the office of the Regional Privacy Professionals Association in Russia, presented the second part of the ICLRC research. The initial presentation of the “heat map” was made during the UNCITRAL Working Group IV session in March 2025. The research revealed two zones in the regulatory landscape of digital trade. The first zone is the fragmentation zone. It consists of countries whose national laws are mostly not harmonized with each other and/or are not based on the UNCITRAL approach (e.g., digital signatures). The second zone is the growth zone, consisting of countries that have not yet implemented any regulations (e.g., automated contracting). This fragmentation requires an interoperability framework that provides adapters to enable digital trade between actors in different countries. Compatibility and interoperability could be added as new principles of digital trade regulation.

Ekaterina Smyshlyaeva, Secretary of the Committee on Economic Reform and Regional Development of the Mazhilis of the Parliament of the Republic of Kazakhstan, stressed the need for consumer protection and the free flow of data in digital trade. She offered examples of regulatory solutions ranging from product traceability to dedicated platforms that require a special approach in the context of international digital trade. As expected, all of these issues will be addressed in the future Digital Code of Kazakhstan.

Temir Kazybay of the National Legal Corporation, shared insights on the preparation and adoption of the Digital Code of the Kyrgyz Republic. The adoption of the Digital Code marked the first multistakeholder process in the Kyrgyz digital sphere. Market players who were previously separated, such as telecommunications carriers and financial institutions, came together at the parliament’s roundtable for the first time to discuss common issues regarding digital trade regulation. Despite the difficulty, a mutually favorable text of the Digital Code was drafted. The Digital Code is expected to be adopted in its third reading by the end of June.

Xiaoming Zhou, the Deputy director of the United Institute of International Organizations in Law at Wuhan University, shared her experience of participating in ICLRC research and possible approaches to implementing this research in current regulatory practices. Her presentation highlighted China's development of an interoperable legal framework for digital trade, including laws on e-commerce, data security, and personal data protection.

Wajahat Khan and Faisal Imtiaz of the Electronic Certification Accreditation Council (ECAC) of the Ministry of IT & Telecom (MoIT&T) of the Government of Pakistan presented on the current state of the implementation of UNCITRAL standards in Pakistani legislation in the electronic sphere. Their presentation highlighted that Pakistan's Electronic Transactions Ordinance (ETO) 2002 was adopted based on UNCITRAL's Model Law on Electronic Commerce (MLEC) 1996 and Model Law on Electronic Signatures (MLES) 2001. The purpose of ETO 2002 in Pakistan is to recognize and facilitate documents, records, information, communications, and transactions in electronic form, and to provide for the accreditation of Certification Service Providers (CSPs). It aims to provide legal sanctity to electronic forms and create trust in electronic transactions.

Tamás Parti, head of the Data Research Institute of MOKK (Hungarian National Chamber of Civil Law Notaries), provided a theoretical overview of the conceptual approach to digital commerce. He emphasized the need to establish clear and consistent conceptual foundations for digital commerce, the data economy, and data trade in order to ensure effective regulation. The speaker highlighted that the data science concepts used to describe digital phenomena are not always suitable for precise interpretation by legal systems, given the diverse approaches of different legal fields. Therefore, legal systems must develop their own more detailed conceptual frameworks — drawing on data science methodologies — to accurately define digital phenomena across various areas of regulation. For instance, it is of fundamental importance to consistently and conceptually distinguish between the terms “data” and “information,” in contrast to approaches that explain data merely through the notion of information.

In his closing remarks, Luca Castellani of the UNCITRAL Secretariat encouraged all participants to engage in discussions during the UNESCAP Digital Trade Week in Bangkok on 9 June 2025, and during the UNCITRAL session in July 2025.