Global momentum – 61 percent of exports now covered by aligned or committed economies

One of the clearest indicators of global momentum is the rapid uptake of the UNCITRAL Model Law on Electronic Transferable Records (MLETR). Approximately 61.5 percent of global exports now originate from jurisdictions that are either aligned with, or formally committed to, MLETR-aligned principles. This accelerating legal convergence represents real progress, but beneath this positive trajectory lies a deeper challenge: legal reform is necessary, but not sufficient. Digital trade only works when digital documents can be issued, transmitted, verified, and accepted across borders. The world today is legally half-ready, but operationally fragmented. Many economies that have enacted enabling laws still lack the administrative and technical capacity to implement them. In other economies, inconsistent coordination between customs, ports, banks, and traders undermines effectiveness. Even where laws are in place, the absence of widespread, interoperable systems often blocks the full potential of electronic bills of lading, warehouse receipts, or other digital instruments at commercial scale.

The implementation gap – turning reform into real-world usage

This global implementation gap has direct implications for Germany. As a highly industrialised and export-oriented economy, Germany already possesses the legal and technological readiness to adopt digital trade processes. But digital trade is inherently collaborative: it only works when partner countries can operate digitally as well. A German exporter can issue an electronic document of title, but if the counterparty or customs authority across the border cannot accept it, the entire process collapses back to paper. German ports, carriers, banks, and manufacturers are therefore constrained not by domestic readiness, but by the readiness of the global system around them.

In DSI’s engagements with more than fifty jurisdictions, the same pattern emerges. Passing a digital trade law rarely produces immediate adoption. Between legislative enactment and widespread usage lies what might be called the “missing middle”: the practical, operational work required to coordinate agencies, onboard industry, build technical trust, ensure system reliability, and test interoperability. Many governments do not know where to begin. Agencies often work in silos. Private-sector actors lack clarity on what constitutes a “reliable system” under MLETR. Financial institutions remain cautious until pilots demonstrate legal certainty and risk clarity. The result? The world has the rules but not yet the routines.

To help countries navigate this implementation gap, the ICC DSI developed the Free Zone Pilot Playbook as the fastest and lowest-risk entry point to test “digital trade”.  

Free zones – fast, flexible testbeds for digital trade

One of the promising paths for rapid implementation is the use of free economic zones. Because of their regulatory flexibility and operational autonomy, free zones can often move faster than national systems. They can test electronic bills of lading, warehouse receipts, and other digital documents without waiting for nationwide procedural updates. Free zones also provide controlled environments in which stakeholders can align workflows, adopt standards, and measure the impact of digital documentation with far fewer administrative hurdles.

This approach is gaining traction. China offers one of the clearest examples of this sequencing: before reforming its national Maritime Code on 28 October this year, the government first authorised the Shanghai Free Trade Zone in December 2023 to pilot the legal use of electronic transferable records, expanded this mandate to all 21 of China’s free trade zones in July 2025, and only then undertook the nationwide legislative reform. This staged pathway – free zone pilots first, national reform second – illustrates how jurisdictions can de-risk innovation while building the evidence base for broader adoption. Case studies from Beijing Two Zones and ADGM are included in the original publication. 

For Germany, these developments are especially significant. Digital corridors created through free-zone pilots abroad can benefit German exporters immediately, even before national legal or technical updates in those partner countries are fully completed. A pilot involving a German carrier and a free zone in Beijing, Lagos, or Dubai has the potential to reduce processing times, accelerate payments, and improve supply-chain transparency for German manufacturers. Free-zone pilots abroad thus become an enabler of Germany’s own digital transformation.