Integrating Omnibus Product Objectives with the European Trade Indexes Registry (EUTIR)

Our feedback addresses the European Commission’s proposal COM(2025) 504 and its annexes, focusing on the integration of the European Trade Indexes Registry (EUTIR) into the New Legislative Framework (NLF). We propose EUTIR as a foundational digital infrastructure that ensures legal validity, traceability, security, and interoperability of electronic trade documents across the EU. Built on Distributed Ledger Technology (DLT) via the European Blockchain Services Infrastructure (EBSI), EUTIR registers metadata records’including cryptographic hashes, timestamps, status indicators, and identifiers’without storing full document content, thus ensuring privacy, immutability, and long-term auditability.