CONVERGENCE AND DIVERGENCE OF CIVIL LEGAL REGULATION OF DATA IN BLOCKCHAIN TECHNOLOGIES: EU DATA ACT EXPERIENCE AND PROSPECTS FOR UZBEKISTAN

The processes of convergence and divergence in civil law regulation of blockchain data are studied using the example of the innovative EU Data Act of 2023. Using methods of comparative legal analysis and legal modeling, the mechanisms of unification of European approaches to smart contract control through mandatory emergency termination functions established by Article 36 of the Act are analyzed. The study demonstrates how the European model creates an unprecedented legal regime that ensures optimal balance between technological autonomy of decentralized systems and imperatives of legal control. The main directions of legal divergence in international practice of blockchain technology regulation have been identified, including cardinal differences in legal qualification of smart contracts, judicial control mechanisms, and jurisdictional approaches of various states and legal families. Special attention is paid to complex problems of cross-border application of national legislation to decentralized networks and acute conflicts of jurisdictions in the rapidly developing international digital space. Specific prospects for adapting European experience of legal convergence for systematic improvement of civil legislation of Uzbekistan in the field of modern digital technologies have been determined, and detailed mechanisms for phased implementation of international standards with mandatory consideration of peculiarities of the national legal system and specific regional factors of sustainable development of digital economy have been proposed.