Blockchain Technology and Smart Contracts in Cross-Border Corporate Governance: A Comparative Analysis of Regulatory Frameworks and Implementation Challenges

Abstract

The digital transformation of corporate governance through blockchain technology and smart contracts represents one of the most significant developments in international business law in the 21st century. This article examines the integration of blockchain-based systems into cross-border corporate governance frameworks, analyzing the legal, regulatory, and practical challenges that multinational corporations face when implementing these technologies across multiple jurisdictions. Through comparative analysis of regulatory approaches in the European Union, United States, United Kingdom, Singapore, and India, this study identifies critical divergences in legal recognition, enforcement mechanisms, and compliance requirements. The research demonstrates that while blockchain technology offers substantial benefits in terms of transparency, efficiency, and automated compliance, significant jurisdictional fragmentation creates operational complexities for international enterprises. Drawing on recent legislative developments, including the EU AI Act (2024), the Global Cross-Border Privacy Rules (2025), and India's evolving digital corporate law framework, this article proposes a harmonized approach to blockchain governance that balances innovation with regulatory oversight. The findings suggest that successful implementation requires not only technological adaptation but also fundamental reconceptualization of corporate governance principles, fiduciary duties, and stakeholder accountability in the digital age. This research contributes to the growing body of scholarship on legal technologies and provides practical guidance for corporate counsel, policymakers, and business leaders navigating the intersection of distributed ledger technology and international corporate law.