Yet the rapid transformation of global trade, accelerated by new legislation, digital standards, real-time data flows, distributed ledgers, tokenisation, and the rise of data-driven compliance, has begun to stretch the documentary paradigm to breaking point. The industry that once relied on paper has evolved into a data-intensive ecosystem in which operational integrity, evidential sufficiency, and payment certainty require more than digital pictures of paper. The documentary credit remains highly relevant, but it increasingly exists in parallel with new forms of digital evidence, new expressions of conditionality, and new models of authoritative data.
Against this backdrop, the ICC has found itself pulled between two worlds. On one hand, the eUCP, the electronic supplement to the UCP, continues to serve as the backbone of digital documentary compliance. On the other, the URDTT, launched with the ambition of creating a rulebook for data-driven, digital-native trade, has yet to find meaningful adoption. The result is a landscape caught between the familiar, the emerging, and the incomplete.
This blog brings these worlds together. It draws on the trade finance industry's experience with eUCP, the unrealised potential of URDTT, and the rapidly changing environment to examine a single question: How do we transition from a document-first to a data-first architecture of trust?
And more importantly, what must URDTT become for the trade finance industry to follow? This is the story of a future that is already unfolding.
The eUCP, introduced in 2002 and now in version 2.1, was designed not to replace the UCP but to extend it into the electronic environment. Its achievement is that it preserves the logic of the documentary credit, presentation, compliance, examination, refusal, dishonour, and honour, while permitting electronic records to serve as documents.
In practice, this means that an eUCP credit behaves exactly like a UCP credit, with the only difference being the medium of evidence. The examiner still assesses whether a document meets the terms of the credit; whether its data conflicts with other required documents; whether a presentation is consistent, timely, and compliant.
What eUCP accomplished was essential: it provided the legal and procedural certainty required for global banks to process electronic presentations without altering the underlying contractual structures. It also created a pathway for the dematerialisation of documents such as bills of lading, insurance certificates, inspection reports, and certificates of origin, provided they conformed to the definitions of electronic records and met the standards of integrity and accessibility.
But the success of eUCP also illustrates its limitation: it is fundamentally a digital reflection of an analogue paradigm. It solves for the electronic exchange of documentary evidence, not the automation of trade flows or the real-time validation of events. It accepts the logic of a world in which documents must be examined manually, even if their form is electronic. It does not accommodate streaming data, IoT-verified events, tokenised payment obligations, programmable conditions, or distributed ledgers.In many respects, eUCP is a triumph of thoughtful evolution. But it is not, and never was intended to be, the rulebook for a fully digital, data-native trade ecosystem.
Even as adoption of eUCP grows, the ecosystem around it is moving faster. New forms of digital evidence, verifiable credentials, distributed ledgers, tokenised obligations, ISO 20022-encoded data messages, interoperable digital identities, are increasingly capable of performing functions that documents historically performed.
The challenge is not that documents are obsolete; it is that documents are no longer the primary source of trust. The industry is shifting from documentary representation to data-based assertion; from manual examination to automated validation; from physical possession to digital control; and from bank-centred workflows to network-centred event architectures.
In this environment, the eUCP can digitise yesterday's workflow, but it cannot construct that of tomorrow. This gap is precisely what the URDTT set out to solve. And yet, URDTT Version 1.0 has remained dormant.
When the URDTT was launched in 2021, it promised to usher in a future of trade finance based on data, not documents. Its creators, experienced ICC practitioners, envisioned a rulebook that would provide a standard structure for digital payment commitments allowing validation based on data rather than documents, enabling event-triggered conditionality, whilst being instrument-agnostic, flexible, interoperable, and digital-native. The aim, to bridge physical, digital, and financial flows was correct. The problem was the timing.
URDTT arrived too early, with too abstract a scope, and without a clear definition of the instrument at its centre. The market did not know what a URDTT undertaking actually was, how it related to existing trade instruments, or what commercial problem it solved that UCP and eUCP did not. The result was predictable in that the market quietly set URDTT aside and returned to what it knew, UCP, eUCP, and collections. But time has moved on. And the world that URDTT was built for is now materialising.
URDTT never clearly articulated whether it governed an instrument, a process, a message exchange, or a digital payment undertaking. This ambiguity prevented banks from understanding what obligations they were taking on, and under what legal framework.
Where UCP has the documentary credit, URC has the collection, and URDG has the demand guarantee, URDTT has no singular, well-defined instrument. Its "digital trade transaction" is conceptually expansive but operationally vague. Without a precise object, such as a digital payment commitment, the market could not anchor URDTT to a commercial workflow.
URDTT was launched into a vacuum. No banks had implemented it. No technology provider had built to it. No regulator had referenced it. No corporate had requested it. Instead of iterative pilot-driven refinement, URDTT emerged as a single monolithic rulebook with no adoption pathway. URDTT was conceptually promising, but practically unusable. Yet none of these flaws were fatal. They were simply premature.
In the years since URDTT's release, the landscape has radically transformed, precisely in the direction URDTT anticipated. We now see MLETR adoption, eBL acceleration, verifiable credentials and digital identity, tokenised trade assets, AI-driven compliance, ISO 20022 expansion, and API-centric ecosystems. In other words, the conditions for URDTT adoption are now present, even if URDTT itself remains incomplete.
Let us imagine a future trade transaction under a mature URDTT 2.0 environment:
A Singapore-based exporter sells specialised machinery to a buyer in Rotterdam. Instead of issuing a documentary credit, the buyer's bank issues a Digital Payment Commitment (DPC) governed by URDTT Version 2.0. This DPC is a binding, irrevocable undertaking encoded as a transferable digital asset on a regulated DLT network. It is identifiable, controllable, and enforceable under MLETR. The conditions of the DPC are not expressed through documents but through data events:
Each event is expressed through structured data, cryptographically signed and time-stamped. The DPC is automatically updated as each event is validated. No document examination occurs. No PDF is submitted. No human checker is needed unless an exception is triggered.
Upon fulfilment of all conditions, the DPC self-executes:
This is not science fiction. Every component of this workflow exists today, just not under a unified rulebook.
eUCP cannot govern this world. URDTT 1.0 cannot govern it either. But URDTT 2.0 could.
URDTT Version 2.0 could introduce a Digital Payment Commitment (DPC) as its anchor instrument, an irrevocable, conditional, digitally native undertaking supported by data presentation (not documents, but structured data sets, digitally signed and time-stamped), and validation events (pre-defined conditional triggers, each referencing a specific data source or trusted authority).
A URDTT DPC could support open account, supply-chain finance, receivables discounting, payables finance, credit insurance, and structured trade products. URDTT 2.0 would not replace UCP or eUCP, it would complete them. And it would provide the missing rulebook for data-first trade.
The ICC faces a strategic choice. Either to let URDTT fade, and the market continues with UCP/eUCP, eBL adoption, ad-hoc platform rules, and proprietary data models. This approach risks fragmentation and a loss of ICC influence. Or, to revitalise URDTT through a structured reform process. This is the preferred path, but requires:
Trade is moving towards an era in which trust is created by data, not documents; by validation, not examination; by control, not possession. ICC must decide whether it will lead or follow. The world is ready for URDTT now. It simply needs a version of URDTT ready for the world.
The transition from eUCP to URDTT is not a shift from one rulebook to another. It is a shift from one philosophy to another: from a world governed by documents to a world governed by data.
eUCP will remain essential and UCP will remain foundational. But URDTT, corrected, refined, and anchored by a clear instrument, can become the rulebook for a digital-native future. A future in which obligations are encoded digitally; events replace documents; data replaces representation; AI reduces burden and risk; settlement is programmable; auditability is inherent; interoperability is expected; and trust is engineered, not inferred.
The industry now sits between what it knows and what it needs. The bridge between them is not technology alone. It is the architecture of rules that turns digital possibility into legal certainty.
URDTT began as an ambitious idea. URDTT Version 2.0 can become the rulebook that defines the next generation of trade.