ABSTRACT
The article is devoted to a comprehensive analysis of the legal regulation of digital assets in leading jurisdictions. It discusses the key aspects of defining and protecting ownership rights to digital assets. The author focuses on how different countries regulate the circulation of these assets, identifying common features and differences in the approaches used in different legal systems. Modern economic relations are evolving under the influence of the latest technologies, forming the digital economy. Digital assets are becoming increasingly widespread in the world, despite significant gaps in their regulation around the world. Given their transnational nature and intangible form, investors may often face an incomplete understanding of how to protect their rights in such assets. National legislation is fragmented and often lacks a sufficient legal basis. There are differences even in the definition of ‘digital assets’. There is also no consensus on which term should be used, leading to fragmentation in legal acts around the world. Today, the European Union has the upper hand in the legal regulation of digital assets, as the Union has adopted the MiCA Regulation, which deeply regulates the issues of digital assets, protection of rights to such assets, and combating illicit trafficking. Nevertheless, this document still leaves a number of open issues related to the ownership of digital assets in civil relations, underscoring the need to improve the existing legislation. The main objective of the study is to analyse the current state of legal regulation of digital assets, identify gaps and propose ways to address them. The authors of the article evaluated legal acts in different jurisdictions, identifying advantages and disadvantages. In addition, the authors of the article reveal the existing challenges associated with insufficient harmonization of international legal standards on digital assets. The novelty of the study lies in the author’s proposed approaches to improving international regulation, including harmonization of legal norms and development of common standards through international organizations such as the United Nations Commission on International Trade Law.
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Yurii Riabchenko, Andrii Onyshchenko, Volodymyr Kudin, Olena Kononets and Viktor Holdskyi, Digital assets and property rights: regulation and legal implications within the EU and globally, Statute Law Review volume 46 issue 3 (December 2025). Published: 1 September 2025.
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