DOI: https://doi.org/10.36719/2706-6185/48/127-143
Baylar Suleymanli
University of Silesia
Master student
https://orcid.org/0009-0006-1893-7020
baylar.suleymanli@mail.ru
Regulatory Frameworks and Government Approaches to Blockchain
(Smart Contracts): European Union, Great Britain, USA,
China, and Comparative Insights
Abstract
This paper analyzes the regulatory frameworks and government policies regarding blockchain and smart contracts in the four of the world's biggest jurisdictions: the European Union, the United Kingdom, the United States of America and China. As blockchain technology, particularly smart contracts, transition from experimental applications to legal and commercial use, the need for regulatory clarity has become paramount. The study begins by outlining the technical and legal character of smart contracts and tracing a spectrum of models of incorporation into traditional contractual forms. It then examines the approach to the law of smart contracts in each jurisdiction, ranging from the EU's harmonization and codification under MiCA and the Data Act, to the UK's common law-based development, the US's patchwork state-level experimentation, and China's centralized and policy-driven legal enforcement. Through comparative visualizations like radar charts, stacked bar graphs, and heatmaps, the paper finds divergent levels of institutional support, crypto integration, consumer protection, and legal certainty. The findings show that even though every jurisdiction resonates with unique regulatory philosophies, they also reflect complementary models of blockchain governance. The article ends with a reemphasis on the need for global cooperation and standardization to enable the secure, efficient, and legally binding application of blockchain technology in international business and governance.
Keywords: Blockchain regulation, smart contracts, Aİ Data Act, MiCA, USA legal fragmentation, China BSN, comparative analysis