Blockchain-based regulatory assurance for sanctions-exposed electricity procurement in post-conflict markets

1 Introduction

Electricity systems form a basic foundation for economic activity and social stability, especially in regions affected by conflict and political disruption, where infrastructure damage and governance gaps often weaken service delivery and financial flows (Moteng et al., 2023; Okafor et al., 2025; Chen et al., 2023). Energy markets in sanctions-exposed settings face pressure from disrupted trade and finance, market fragmentation, and lower investment confidence, which can impede energy-sector recovery (Okafor et al., 2025; Omokaro et al., 2025). In these conditions, electricity procurement is especially vulnerable to weak documentation, compliance uncertainty, and payment friction, all of which can increase transaction risk and reduce confidence among counterparties.

Post-conflict electricity procurement is nevertheless distinct from conventional high-risk public procurement because several forms of institutional and operational disruption occur simultaneously. Physical damage creates urgent and technically interdependent purchasing needs, while fragmented administrative authority may leave procurement approval, regulatory supervision, technical certification, and payment authorization distributed across institutions with uneven capacity. Reconstruction urgency can compress ordinary tender and verification timelines, yet sanctions exposure may simultaneously intensify beneficial-ownership checks, counterparty screening, and scrutiny of cross-border payment routes. Documentary continuity may also be weakened by damaged administrative systems, personnel turnover, incomplete archives, and contested institutional authority. These conditions create a distinctive assurance problem: procurement decisions must be made rapidly while remaining attributable, legally reviewable, compliance-screened, financially credible, and capable of later verification. Accordingly, the relevant design question is not simply whether blockchain can improve transparency or transaction efficiency, but how a digital record architecture can preserve procurement assurance when institutional continuity, documentary reliability, and payment confidence are simultaneously impaired (Moteng et al., 2023; Mohamed and Mohammed Khalifah, 2026).

Digital technologies have been discussed as possible tools to improve transparency and coordination in energy markets, with blockchain receiving strong attention due to its decentralized structure and ability to record transactions in an immutable way (Andoni et al., 2019; Roth et al., 2022; Hassan et al., 2019). Research shows that blockchain systems can support secure data sharing, reduce reliance on centralized intermediaries, and improve transaction verification processes in energy networks (Mollah et al., 2021; Dong et al., 2018; Chen et al., 2022). These features are considered useful in complex environments where trust between parties is limited and regulatory capacity is uneven, particularly in electricity markets that involve multiple actors and contractual layers (Jiang et al., 2025; Egunjobi et al., 2024; Brilliantova and Thurner, 2019).

A large body of literature focuses on blockchain applications in decentralized energy trading and peer to peer electricity markets, where smart contracts enable automated transactions and settlement between producers and consumers (Wongthongtham et al., 2021; Esmat et al., 2021; Nykyri et al., 2022). Studies also examine blockchain-based platforms for microgrids, local flexibility markets, and transactive energy systems, which aim to improve efficiency and coordination in distributed energy environments (Antal et al., 2021; Hua et al., 2020; Mazrae et al., 2025). These works highlight technical design, system performance, and operational benefits, with less focus on regulatory integration or legal enforceability in complex governance settings (Santos et al., 2025; Tariq and Amin, 2025; Kirli et al., 2022).

Research has also addressed blockchain in energy trading from a privacy and security perspective, where different methods are proposed to protect user data while maintaining accountability and transparency (Wang et al., 2023; Zhang et al., 2026; Erdayandi et al., 2025). Hybrid blockchain systems, permissioned networks, and encryption techniques have been studied to balance openness with confidentiality requirements, especially in electricity markets that involve sensitive commercial and operational data; (Khorasany et al., 2021; Alam et al., 2024). These technical approaches contribute to system design but do not fully address how such systems interact with legal standards, contractual obligations, and regulatory enforcement (Lei et al., 2022; van Leeuwen et al., 2020; Christidis et al., 2021).

Public-sector and procurement related studies show that blockchain can support transparency, reduce corruption risks, and improve traceability in contracting processes, especially in environments where institutional trust is weak (Govindan et al., 2024; Rai et al., 2024; Ibrahimy et al., 2024). Governance models for blockchain in public administration emphasize accountability, data control, and role allocation among stakeholders, which are important for regulatory acceptance and system legitimacy (Tan et al., 2022; De Matteis et al., 2025; Diestelmeier, 2019). These discussions indicate that blockchain adoption requires alignment with legal frameworks and policy objectives, rather than focusing only on technical efficiency (Brilliantova and Thurner, 2019; Chen et al., 2022; Hassan et al., 2019).

At the same time, studies on sanctions and energy markets show that financial restrictions, compliance requirements, and political risks can disrupt energy supply chains and limit access to international transactions (Moteng et al., 2023; Okafor et al., 2025; Omokaro et al., 2025). Payment delays, banking restrictions, and risk aversion among financial institutions create serious challenges for electricity procurement, especially in post-conflict settings where urgent reconstruction is required (Chen et al., 2023; Hatipoglu et al., 2023; Nandnaba, 2025). These conditions increase the need for mechanisms that can provide assurance to regulators, investors, and contractors while maintaining compliance with international rules (Mathieu and Valenzuela, 2025; Okafor et al., 2025).

Despite the wide literature on blockchain in energy and procurement, limited attention is given to how blockchain records can support legally recognized and reviewable regulatory evidence in sanctions-exposed electricity markets. Existing studies focus more on technical design and decentralized trading models, while the connection between blockchain systems and legal accountability in procurement processes remains unclear. There is also limited discussion on how such systems can support sanction compliant payments and dispute resolution without increasing exclusion or surveillance risks (Shwan et al., 2025; Haji et al., 2026).

The aim of this study is to develop a legal and institutional framework that connects blockchain-based records with regulatory systems in electricity procurement, allowing procurement actions and contract milestones to be documented in forms capable of supporting legal and regulatory review.

Existing studies provide important insights into blockchain-enabled transparency, procurement traceability, smart-contract automation, energy transactions, and digital compliance. However, these strands remain fragmented. Blockchain procurement studies predominantly emphasize transparency and transaction efficiency; energy-blockchain research largely focuses on trading, decentralization, and technical applications; and compliance-oriented studies typically examine individual mechanisms such as identity verification, sanctions screening, or auditability. What remains insufficiently developed is an integrated governance model explaining how these capabilities should interact when electricity procurement simultaneously faces institutional fragmentation, sanctions exposure, documentary uncertainty, sensitive information requirements, payment risk, and the possibility of subsequent legal or regulatory challenge. This unresolved integration problem constitutes the principal research gap addressed by the present study (Mohamed, 2025; Tan, 2023).

The contribution of this study does not lie in proposing permissioned blockchain, cryptographic hashing, role-based access, or distributed audit trails as individually novel mechanisms. Rather, it lies in integrating these established capabilities within a regulatory assurance architecture specifically configured for sanctions-exposed post-conflict electricity procurement. The framework connects six governance functions—legal recognition, institutional role allocation, compliance and beneficial-ownership verification, controlled data governance, performance and payment assurance, and dispute readiness—that are commonly treated separately across blockchain, procurement, sanctions-compliance, and public-governance research. By linking these functions to the interacting vulnerabilities of institutional fragmentation, documentary disruption, cross-border compliance exposure, payment uncertainty, and weakened review capacity, the study shifts the analytical focus from blockchain-enabled transparency alone toward the broader problem of maintaining legally and institutionally reviewable procurement under conditions of governance fragility. Methodologically, the study employs a conceptual and doctrinal synthesis, as detailed in Section 3, to derive the regulatory assurance framework from the relevant literature and legal-governance considerations. The proposed framework is conceptual and jurisdiction-neutral rather than an empirically validated implementation model; consequently, its legal recognition, institutional configuration, and practical operation must be assessed against the applicable rules and capacities of individual jurisdictions (Tan et al., 2022; Chen et al., 2023; Moteng et al., 2023).

Figure 1 presents the structural progression from post-conflict conditions through procurement and payment failure toward the need for a regulatory assurance framework.

2 Literature review

2.1 Electricity procurement in post-conflict contexts

Electricity procurement in post-conflict contexts is shaped by urgency, damaged infrastructure, weak administrative capacity, and unstable financing conditions (Berhe et al., 2026). Reconstruction periods often require rapid purchasing of fuel, spare parts, generation equipment, and network rehabilitation services, yet these transactions take place in settings where market rules are often unsettled and institutional authority may be divided or incomplete (Moteng et al., 2023; Mathieu and Valenzuela, 2025; Chen et al., 2023). Energy poverty tends to deepen in sanctioned and crisis affected economies, and this places extra pressure on public authorities to secure electricity inputs quickly even when procurement systems are under strain (Okafor et al., 2025; Moteng et al., 2023; Nandnaba, 2025). Research on sanctions and energy disruption shows that geopolitical pressure can affect fuel access, repair schedules, investment confidence, and the wider operation of energy markets, making procurement decisions more exposed to external risk and domestic uncertainty (Hatipoglu et al., 2023; Omokaro et al., 2025; Chen et al., 2023).

Recent electricity-governance scholarship shows renewed state intervention and political contestation in electricity policy, but this literature is not specific to post-conflict procurement (Mathieu and Valenzuela, 2025; Tuladhar et al., 2024). In such settings, procurement cannot be treated as a simple commercial function because it sits within a wider field of legal control, financial screening, and public accountability (Govindan et al., 2024; Tan et al., 2022; De Matteis et al., 2025). Public procurement studies from other sectors further indicate that low visibility in contract formation and delivery increases opportunities for rent seeking, payment disputes, and non-performance, especially where documentation systems are fragmented (Rai et al., 2024; Ibrahimy et al., 2024; Govindan et al., 2024). Table 1 summarizes how the literature links post-conflict electricity procurement with sanctions pressure, governance fragility, and documentation problems. At the same time, the available source base is stronger on sanctions related energy disruption, public governance, and blockchain enabled procurement than on direct studies of post-conflict electricity reconstruction procurement itself. For that reason, the present review draws an analytical connection across these adjacent fields rather than claiming that a large, unified literature already exists on blockchain-based regulatory assurance in post-conflict electricity procurement. The literature therefore suggests that procurement in post-conflict electricity markets is a legal and institutional problem as much as a logistical one, and this point creates the foundation for later discussion of regulatory assurance mechanisms.

TABLE 1. Post-conflict electricity procurement, sanctions pressure, and core governance concerns in the literature.

These conditions distinguish post-conflict electricity procurement from conventional high-risk public procurement in an important respect: governance failures are mutually reinforcing rather than isolated. Infrastructure damage increases procurement urgency, but urgency can weaken ordinary verification and competitive safeguards. Fragmented authority complicates responsibility for tender approval, technical certification, compliance review, and payment authorization, while weakened administrative capacity may reduce the reliability and continuity of procurement documentation. At the same time, dependence on imported equipment, foreign contractors, external finance, and cross-border payment channels can increase exposure to sanctions screening, beneficial-ownership verification, banking restrictions, and counterparty risk. A procurement system designed for this environment must therefore accommodate speed without abandoning verification, distribute authority without losing accountability, and preserve documentary continuity despite institutional disruption (Govindan et al., 2024; Ibrahimy et al., 2024).

These characteristics translate into specific design requirements for regulatory assurance. Fragmented institutional authority requires attributable roles and permissioned participation; disrupted documentary systems require persistent and independently verifiable records; sanctions exposure requires compliance screening and beneficial-ownership verification before award and payment; financing and payment uncertainty require traceable milestone certification and payment authorization; confidentiality and infrastructure-security concerns require differentiated rather than unrestricted transparency; and weakened dispute-resolution capacity increases the importance of preserving reviewable evidence for subsequent administrative, arbitral, or judicial examination. The post-conflict context therefore does not merely provide an application setting for the proposed blockchain framework. It determines the governance functions that the framework must perform (Tuladhar et al., 2024; Moteng et al., 2023).

2.2 Governance failures and trust deficits in sanctions-exposed markets

Governance failure in sanctions-exposed markets usually appears through weak oversight, fragmented responsibility, opaque contracting chains, and hesitation among banks or counterparties that fear compliance breaches. Studies on sanctions and energy poverty show that restrictions on trade and finance can deepen shortages and raise transaction costs in already fragile economies, while unilateral and multilateral sanction regimes may produce different levels of strain across target states (Moteng et al., 2023; Okafor et al., 2025; Omokaro et al., 2025). Energy sanctions are also associated with market disruption, transition pressures, and wider environmental consequences during geopolitical crises (Hatipoglu et al., 2023; Chen et al., 2023; Nandnaba, 2025). These conditions weaken trust because firms, regulators, and lenders cannot easily verify whether procurement actions are lawful, complete, and free from diversion risk (Uche-Soria et al., 2025; Haselbarth et al., 2023).

Public-sector blockchain governance studies help explain why trust problems remain severe when institutional roles are unclear and data flows are poorly controlled. Conceptual work on blockchain governance in public administration stresses that technical systems need clear authority allocation, decision rights, and accountability rules before they can support administrative legitimacy (Tan et al., 2022; De Matteis et al., 2025; Ibrahimy et al., 2024). Procurement scholarship reaches a similar point, arguing that digitization alone cannot cure corruption risk when the surrounding governance model fails to specify who records, verifies, audits, and challenges transactions (Govindan et al., 2024; Rai et al., 2024; Ibrahimy et al., 2024). Energy sector writing also notes that trust in digital platforms depends on market design, legal recognition, and accepted dispute pathways, rather than on data immutability alone (Andoni et al., 2019; Chen et al., 2022; Hassan et al., 2019).

Recent implementation research has also demonstrated the feasibility of blockchain-anchored, tamper-evident energy logging, illustrating how cryptographically verifiable audit trails can support distributed energy-data integrity even under intermittent connectivity conditions (Vasheghani Farahani and Treiblmaier, 2025).

The trust deficit is therefore produced by legal uncertainty as much as by technical weakness. A sanctions-exposed electricity market may have digital records, yet those records have little effect if banks do not accept them, regulators cannot act on them, and contractors cannot rely on them in a dispute. Table 2 brings these themes together and shows that the governance problem centers on record credibility, role clarity, and compliance assurance. This reading of the literature points toward the need for a permissioned and legally framed model rather than a purely transactional blockchain design.

TABLE 2. Governance failures and trust deficits in sanctions-exposed electricity markets.

2.3 Blockchain applications in energy and public procurement

The blockchain literature in energy has grown quickly and covers peer to peer trading, smart contracts, local flexibility markets, settlement systems, billing, and distributed market coordination. Review studies describe the field as technically rich, with repeated attention to decentralization, traceability, automation, and reduced dependence on central intermediaries (Andoni et al., 2019; Roth et al., 2022; Egunjobi et al., 2024). Surveys also show that blockchain has been applied to transactive energy, microgrids, and multi energy trading arrangements, where system designers aim to improve transactional speed, market matching, and settlement integrity (Jiang et al., 2025; Tariq and Amin, 2025). Work on smart contracts further explains how automated execution can support market management, payment logic, and trading rules, especially in decentralized electricity systems (Kirli et al., 2022; Thomas et al., 2019; Santos et al., 2025).

Empirical and design-oriented studies present a wide range of models, including peer to peer trading platforms, hybrid blockchains, permissioned systems, and optimization linked trading frameworks (Wongthongtham et al., 2021; Esmat et al., 2021; Chen et al., 2021). Other studies examine balance settlement ledgers, local flexibility markets, carbon linked trading, hybrid microgrids, bilateral trading in microgrid communities, and socially optimal transactive systems (Nykyri et al., 2022; Antal et al., 2021; Hua et al., 2020; Sindi et al., 2024; van Leeuwen et al., 2020; Yang and Wang, 2021). Research also addresses privacy and security through homomorphic encryption, privacy preserving matching, lightweight frameworks, hybrid architectures, and protected trading strategies (Khorasany et al., 2021; Wang et al., 2023; Mu et al., 2023; Erdayandi et al., 2025; Zhang et al., 2026). These studies strongly support blockchain as a trusted cyber infrastructure for future energy systems, while also recognizing scalability, governance, and legal adoption limits (Dong et al., 2018; Mollah et al., 2021; Brilliantova and Thurner, 2019).

Public procurement studies add another dimension. Blockchain has been discussed as a route for traceability, anti-corruption control, and Procurement 4.0 reform, with applications in sectors such as healthcare and public administration (Govindan et al., 2024; Rai et al., 2024; De Matteis et al., 2025). Even so, as shown in Table 3, most applications center on transaction efficiency, trading architecture, and data integrity. The literature gives less direct attention to electricity procurement under sanctions pressure, where legal effect, evidentiary standing, and compliance screening matter as much as transaction recording.

TABLE 3. Comparative map of blockchain applications in energy and public procurement literature.

2.4 Legal recognition, compliance, and limits of digital ledger systems

Legal recognition remains one of the least developed areas in the blockchain energy literature. Many studies accept that ledger entries can improve traceability and create trusted data environments, yet fewer works explain how those entries become enforceable records in regulatory, contractual, or evidentiary settings (Chen et al., 2022; Jiang et al., 2025; Egunjobi et al., 2024). Policy oriented analysis in electricity law indicates that blockchain can alter the role of market participants and can affect legal relationships in regulated systems, though this depends on statutory fit, regulatory acceptance, and institutional design rather than on code alone (Diestelmeier, 2019; Brilliantova and Thurner, 2019; Roth et al., 2022). Smart contract reviews reach a related conclusion, showing that automation can support execution logic, yet failures, coding errors, and rigid triggers create legal questions around liability, reviewability, and remedies (Kirli et al., 2022; Thomas et al., 2019; Santos et al., 2025).

The legal treatment of blockchain-supported procurement records should also be situated within established electronic-transactions and digital-authentication frameworks. UNCITRAL instruments provide technology-neutral principles of non-discrimination, functional equivalence, reliability, integrity, and electronic authentication that can support the legal recognition of electronically generated records without granting blockchain technology a special legal status. In particular, the UNCITRAL Model Law on Electronic Commerce and Model Law on Electronic Signatures establish general principles for electronic records and signatures, while the Model Law on Electronic Transferable Records further emphasizes reliable methods for identification, control, and integrity of electronic records. These instruments support the framework’s underlying position that legal effect derives from compliance with applicable legal requirements concerning attribution, reliability, integrity, and accessibility rather than from immutability alone (UNCITRAL, 1996; UNCITRAL, 2001; UNCITRAL, 2017).

Sanctions and beneficial-ownership verification likewise require reference to the competent regulatory regime rather than reliance solely on generalized blockchain-compliance principles. Official sanctions guidance may specify jurisdictional scope, ownership-and-control criteria, reporting duties, licensing possibilities, and enforcement expectations. For example, United Kingdom Office of Financial Sanctions Implementation guidance addresses the scope of financial sanctions, ownership and control, reporting, exceptions and licensing, compliance, and enforcement. Such authoritative materials reinforce the need for the proposed framework to record the applicable legal basis, relevant ownership-and-control assessment, and institutional compliance decision rather than treating sanctions screening as a universal automated test (OFSI, 2026).

Beneficial-ownership verification should similarly be informed by authoritative standards concerning the identification of natural persons who ultimately own or control legal entities, with FATF guidance providing an important international reference for transparency and beneficial-ownership controls (FATF, 2023).

Compliance questions are even more serious in sanctions-exposed markets. However, the present literature base is stronger on the economic and operational effects of sanctions than on the detailed legal architecture of sanctions screening, beneficial-ownership verification, AML and KYC compliance, correspondent banking de-risking, and the evidentiary treatment of electronic procurement records. The compliance layer developed in this study should therefore be understood as a structured governance proposal rather than as a complete statement of existing compliance law or banking practice. In practice, electricity procurement under external restrictions may require beneficial-ownership checks, sanctions screening, payment-route review, auditable milestone verification, and controlled data access for regulators and financial institutions. The sanctions literature makes clear that payment interruption and de-risking can obstruct energy delivery even where underlying activities are socially necessary (Moteng et al., 2023; Okafor et al., 2025; Omokaro et al., 2025). At the same time, privacy-focused blockchain studies warn that transparency without limits can expose commercially sensitive data or create intrusive monitoring structures (Erdayandi et al., 2025; Wang et al., 2023; Zhang et al., 2026). Public-sector governance scholarship therefore stresses bounded disclosure, role-based permissions, and auditable accountability as conditions for acceptable deployment in regulated settings (Tan et al., 2022; Ibrahimy et al., 2024; Lee and Khan, 2022).

The literature therefore supports blockchain as a record and coordination tool, yet it does not fully resolve how legal status should attach to entries, how automated actions should remain reviewable, or how compliance and rights concerns should be balanced in procurement settings. Table 4 presents this unresolved field in summary form. This unresolved area is directly connected to the present study, which addresses regulatory assurance rather than blockchain adoption in the abstract.

TABLE 4. Legal recognition, compliance, and rights related limits of blockchain-based procurement records.

Taken together, the literature establishes the potential value of blockchain for transparency, traceability, distributed verification, and programmable coordination, but it does not yet provide a sufficiently integrated regulatory architecture for sanctions-exposed post-conflict electricity procurement. In particular, existing approaches rarely connect the legal status of digital records, institutional allocation of authority, beneficial-ownership and sanctions compliance, differentiated information access, performance-linked payment controls, and dispute readiness within a single governance model. The present study addresses this fragmentation by treating these elements as interdependent regulatory-assurance functions rather than as isolated blockchain applications (Ibrahimy et al., 2024; Wang et al., 2023).

3 Methodology

3.1 Research design

This study adopts a conceptual and doctrinal research design to develop a regulatory assurance framework for blockchain-supported electricity procurement in sanctions-exposed post-conflict environments. The study does not seek to test causal relationships empirically or evaluate a deployed blockchain system. Instead, it integrates concepts and findings from several bodies of scholarship to identify the legal, institutional, compliance, informational, financial, and dispute-related functions required for regulatory assurance. The conceptual approach is appropriate because the research problem lies at the intersection of domains that are commonly examined separately, including blockchain-enabled energy systems, public procurement governance, post-conflict reconstruction, sanctions-related market disruption, and legal recognition of digital records.

The methodological components of the study serve distinct purposes. The doctrinal element is used to examine legal and regulatory questions concerning evidentiary recognition, procurement validity, compliance, data governance, and dispute resolution. The literature-review element synthesizes relevant scholarship across blockchain, energy, procurement, governance, and sanctions-related research. Conceptual framework development integrates the recurring problems and governance requirements identified across these sources into the six-layer model, while the normative institutional-design element specifies how institutional roles, validation responsibilities, access controls, and review mechanisms should be organized within the proposed architecture. These components are complementary but analytically distinct.

3.2 Source domains and selection

The source base was organized around the principal domains required by the research question: (1) blockchain applications in electricity and energy systems; (2) blockchain-enabled procurement, traceability, and public-sector governance; (3) electricity procurement and infrastructure reconstruction in post-conflict or institutionally fragile environments; (4) sanctions-related energy disruption, financial restrictions, beneficial-ownership concerns, and payment risk; and (5) legal and regulatory scholarship concerning electronic records, blockchain evidence, smart contracts, data governance, and dispute resolution. Sources were selected for their direct relevance to one or more of these domains and for their capacity to clarify either the procurement vulnerabilities addressed by the study or the governance mechanisms available to respond to them. Particular attention was given to peer-reviewed studies addressing regulated or public-sector applications rather than blockchain applications concerned exclusively with cryptocurrency or decentralized trading.

The review was therefore purposive and problem-oriented rather than a systematic review intended to exhaustively identify all publications on blockchain or electricity markets. Sources were compared across domains to identify recurring governance requirements, areas of convergence, and unresolved regulatory issues. Legal and regulatory claims were treated separately from technical claims because questions such as evidentiary recognition, procurement validity, sanctions compliance, data protection, and contractual enforceability depend upon applicable legal and institutional arrangements.

The framework is jurisdiction-neutral at the conceptual level and does not assume that blockchain records possess uniform legal status across jurisdictions. Legal recognition, admissibility, procurement validity, sanctions compliance, data protection, contractual enforceability, and dispute-resolution authority remain subject to the applicable domestic and international legal framework. Accordingly, the analysis identifies governance functions that require legal implementation, but it does not treat any specific blockchain record, automated action, or compliance decision as legally effective solely by virtue of its technological form.

Source selection was guided by conceptual relevance to the research problem and by the need to represent the principal legal, governance, technical, and sectoral dimensions of the proposed framework. Academic literature provides the primary analytical base for identifying recurring problems and governance mechanisms, while legal and regulatory materials are treated as higher-authority sources when the manuscript makes claims concerning legal recognition, compliance obligations, evidentiary status, or institutional authority.

3.3 Framework derivation

Framework development proceeded through an integrative conceptual synthesis. First, the literature was used to identify recurrent vulnerabilities affecting electricity procurement in sanctions-exposed post-conflict settings, including fragmented institutional authority, documentary discontinuity, compliance exposure, confidentiality requirements, payment uncertainty, and limited dispute readiness. Second, these vulnerabilities were translated into corresponding regulatory-assurance requirements: legally usable records, attributable institutional authority, embedded compliance verification, controlled information access, verifiable performance and payment controls, and reviewable dispute pathways. Third, conceptually overlapping requirements were consolidated into six governance functions that form the proposed framework: legal recognition, institutional governance, compliance verification, data governance, performance assurance, and dispute readiness. Finally, the relationships among these functions were examined across the procurement lifecycle to specify relevant inputs, responsible institutional actors, validation requirements, controlled outputs, and review mechanisms.

Six functions were retained because they represented the minimum non-overlapping governance domains needed to cover the recurrent requirements identified in the synthesis; additional issues identified in the literature could be allocated within these domains without requiring a separate governance function.

The resulting framework should therefore be understood as an analytically derived conceptual model rather than a tested technical architecture. Its purpose is to organize the governance conditions under which blockchain-supported procurement records could contribute to regulatory assurance. The framework is subsequently evaluated through comparison with the legal, governance, compliance, privacy, performance, and dispute-related concerns identified in the literature. Empirical validation, jurisdiction-specific legal testing, and technical implementation remain matters for future research.

4 Proposed framework

4.1 Proposed framework architecture

The proposed framework is developed as a legal and institutional response to the structural procurement problem identified in this study. The central concern is that post-conflict electricity procurement takes place in settings marked by damaged infrastructure, fragmented authority, weak administration, compliance pressure, and unstable payment confidence. In such conditions, a procurement record cannot serve its intended function unless it is legally recognized, institutionally controlled, and linked to a reviewable payment and dispute system. The framework therefore treats blockchain as a regulatory assurance structure for procurement records, rather than as a simple transaction platform or a narrow technical solution. This orientation departs from much of the energy blockchain literature, which mainly concentrates on peer-to-peer exchange, settlement, and decentralized market coordination, while giving less attention to procurement legality, evidentiary use, and administrative control (Andoni et al., 2019; Roth et al., 2022; Jiang et al., 2025).

Figure 2 presents the framework as a six-layer model. The first layer addresses legal status of ledger records. The second establishes permissioned institutional governance. The third introduces compliance and ownership verification. The fourth concerns data governance and rights protection. The fifth addresses performance and payment assurance. The sixth provides dispute readiness and bounded automation. This sequencing is deliberate. A procurement ledger has little effect unless the law recognizes the records it generates. Governance must then determine who may create, validate, review, and rely on those records. Compliance controls must follow because sanctions-exposed procurement cannot be separated from ownership verification and payment route scrutiny. Data governance then limits exposure of sensitive material. Performance assurance links documented milestones to release conditions. Dispute readiness ensures that the record system remains legally usable when conflict arises (De Matteis et al., 2025).

The architecture is specifically shaped by the interacting governance conditions identified in post-conflict electricity procurement rather than by blockchain functionality alone. Fragmented administrative authority creates a need for attributable institutional roles and permissioned participation; disrupted documentary systems require persistent and independently verifiable procurement records; sanctions exposure and dependence on cross-border contractors and financial channels require embedded compliance and beneficial-ownership verification; sensitive commercial, personal, and infrastructure information requires differentiated access rather than unrestricted transparency; payment uncertainty and reconstruction urgency require traceable milestone verification and controlled payment authorization; and weakened or contested institutional environments increase the importance of preserving evidence for subsequent administrative, arbitral, or judicial review. These requirements provide the functional basis for the framework’s legal recognition, institutional governance, compliance verification, data governance, performance assurance, and dispute-readiness layers (Vasheghani Farahani and Treiblmaier, 2025; Tan, 2023).

The six layers should therefore be understood as mutually reinforcing governance functions rather than as generic technical components of a blockchain system. Their purpose is to preserve regulatory assurance where procurement must proceed under conditions of institutional fragmentation, documentary uncertainty, sanctions exposure, financing constraints, and heightened accountability requirements. Blockchain provides the shared record infrastructure through which these functions can be coordinated, but the framework assigns legal interpretation, compliance judgment, technical certification, payment authorization, and dispute resolution to the competent institutions rather than to the ledger itself (De Matteis et al., 2025; Ibrahimy et al., 2024).

Technically, the framework therefore favors a permissioned and identity-based record architecture not because such architecture is novel in itself, but because attributable participation, controlled validation, differentiated visibility, and persistent auditability correspond directly to the governance constraints of sanctions-exposed post-conflict procurement (De Matteis et al., 2025).

Table 5 sets out the architecture in operational terms by matching each framework layer with its related inputs, institutional actors, and controlled outputs. This structure is consistent with public-sector blockchain scholarship, which shows that digital record systems gain administrative legitimacy only when authority, accountability, and access rights are clearly specified (Tan et al., 2022; Ibrahimy et al., 2024; De Matteis et al., 2025). It also reflects procurement research showing that documentation systems must support review, traceability, and role separation if they are to reduce corruption and performance failure in sensitive markets (Govindan et al., 2024; Rai et al., 2024; Ibrahimy et al., 2024). The framework is therefore designed as a layered assurance model in which legality, governance, compliance, confidentiality, performance, and remedy are treated as connected elements of a single procurement structure.

TABLE 5. Full architecture of the proposed framework for blockchain-based regulatory assurance in sanctions-exposed electricity procurement.

Accordingly, the novelty of the framework resides in its configuration and governance logic rather than in the underlying blockchain mechanisms considered individually. Its distinctive feature is the integration of legal, institutional, compliance, informational, performance, and dispute-related controls around the procurement lifecycle, with each function responding to a specific vulnerability associated with sanctions-exposed post-conflict reconstruction (Mohamed and Khalifah, 2024).

Prior public-sector blockchain governance research has examined governance decisions concerning infrastructure, applications, interoperability, consensus, incentives, accountability, organizational arrangements, and control across multiple levels of analysis (Tan, 2023). The present framework complements this governance-oriented perspective but adopts a different organizing logic: rather than structuring the analysis primarily around blockchain governance decisions, it uses the procurement lifecycle and its regulatory vulnerabilities as the organizing unit. It consequently integrates legal recognition, institutional authority, sanctions and ownership review, differentiated information access, performance-linked payment assurance, and dispute readiness within a single regulatory assurance architecture for sanctions-exposed post-conflict electricity procurement (Mohamed and Khalifah, 2024).

4.2 Legal status of ledger records and evidentiary value

The first operative element of the framework concerns the legal status of ledger records. Electricity procurement in fragile and sanctions-exposed settings often suffers from documentary weakness, fragmented record custody, and uncertainty about which records can later support audit, payment review, or dispute resolution (Su, 2025). A blockchain system cannot correct that problem merely by storing transactions in time-stamped form. Legal effect depends on whether the record is recognized as attributable, intelligible, reviewable, and linked to an authorized source. This section therefore proposes that ledger entries should function as regulated procurement records only when they are tied to defined record classes, authenticated signers, preserved hash links, and a controlled audit trail. This approach responds to the gap identified in the literature, where blockchain is often treated as traceable and immutable, yet its evidentiary and regulatory status remains insufficiently developed (Chen et al., 2022; Egunjobi et al., 2024; Kirli et al., 2022).

Figure 3 shows the proposed data architecture for legally usable blockchain records. Procurement source records, including tender documents, bid files, ownership declarations, milestone certificates, invoices, and complaints, remain the substantive documentary base of the procurement process. These source records are not collapsed into the ledger itself. Instead, the framework records a blockchain event entry containing the record class, hash, time-stamp, authorized signer, status, correction history, and audit continuity. The full file is then preserved in an encrypted document repository, while sensitive ownership material may move through a restricted compliance workspace. This model allows the ledger to serve as a structured evidentiary spine without forcing all material into one exposed environment.

The legal importance of this architecture lies in its separation between evidentiary indexing and full documentary content. Electricity law and blockchain scholarship indicate that digital systems may affect regulated transactions only where institutional recognition and legal fit are present, rather than through technical design alone (Diestelmeier, 2019; Brilliantova and Thurner, 2019; Roth et al., 2022). Smart contract literature also warns that code-based execution cannot replace legal review where authority defects, mismatched records, or disputed milestones exist (Thomas et al., 2019; Kirli et al., 2022). For that reason, the ledger under this framework is not the contract itself and not the sole evidentiary source. It is the controlled record layer that preserves integrity, sequence, and attributable status. Figure 3 therefore supports a legally cautious model in which blockchain records become usable because they are embedded in a broader documentary and regulatory structure (Santos et al., 2025).

The legal consequences of this architecture remain jurisdiction-dependent. Recognition of electronic records, evidentiary admissibility, digital signatures, procurement documentation requirements, contractual validity, and judicial or arbitral reliance may differ across legal systems. The framework therefore does not assume that a ledger entry becomes enforceable merely because it is immutable, authenticated, or time-stamped. Rather, it requires implementation to be mapped against the applicable rules governing electronic evidence, procurement, contracting, and dispute resolution in the jurisdiction concerned (Diestelmeier, 2019; Roth et al., 2022).

4.3 Institutional roles and permissioned access structure

The framework adopts a permissioned institutional model because electricity procurement under sanctions exposure requires identifiable public and quasi-public actors, defined decision rights, and controlled access to records. Open blockchain architectures are poorly suited to this context because procurement actions must be attributable to specific institutions and officers. Tender issue, evaluation, ownership checking, milestone certification, treasury approval, and bank release each carry different legal consequences. A system that fails to distinguish those roles would reproduce the governance confusion already present in fragile procurement environments. The literature on public-sector blockchain governance consistently shows that administrative credibility depends on clear role allocation, decision authority, and review pathways, rather than on decentralization as an end in itself; (De Matteis et al., 2025; Ibrahimy et al., 2024; Mladenov et al., 2022).

Validation should likewise reflect institutional competence rather than simple network participation. Technical or engineering milestones should be certified by authorized technical actors, compliance decisions by designated compliance functions, procurement approvals by the competent procurement authority, and payment authorization by the responsible financial institution. The ledger records the resulting institutional actions and their sequence; it does not transfer substantive decision-making authority from those institutions to blockchain validators (De Matteis et al., 2025).

Figure 4 sets out the permissioned governance structure and record visibility model. At the center sits the permissioned blockchain record layer, defined through identity-based access, time-stamped records, and audit continuity. Around that core is the consortium governance layer, which includes the procuring utility, procurement regulator, electricity regulator, treasury and payment agent, and audit and engineer functions. This arrangement creates a record environment in which authorized writing and review are assigned to institutions with defined procurement, technical, financial, and supervisory responsibilities.

The same figure also shows why governance cannot be separated from visibility control. The public visibility layer contains the public procurement portal, market participants, and public observers, but it receives filtered metadata only. Sensitive ownership files, sanctions screening results, and identity data sit in the restricted compliance core, with access limited to authorized compliance users. This matters because procurement transparency must be balanced against confidentiality duties, especially where sanctions exposure, personal data, and commercial sensitivity intersect. Studies on privacy preserving blockchain systems in energy markets support this restricted access logic, particularly in permissioned and hybrid arrangements where transactional trust must coexist with confidentiality control (Wang et al., 2023; Zhang et al., 2026; Erdayandi et al., 2025).

The institutional structure therefore does two things at once. It allocates authority among procurement, regulatory, technical, and payment actors, and it separates public disclosure from restricted compliance review. This is consistent with procurement scholarship emphasizing role separation and auditable control as safeguards against misuse, favoritism, and undocumented decision making (Govindan et al., 2024; Rai et al., 2024; Ibrahimy et al., 2024). The framework thus relies on permissioned governance because regulated procurement requires accountable institutions, not anonymous network participation.

The choice of a permissioned architecture responds directly to the institutional conditions of post-conflict procurement. Fragmented authority requires the system to identify which institution is authorized to initiate, validate, certify, approve, or review each procurement action rather than relying on anonymous network participation. Weak documentary continuity requires validated actions to remain attributable to identifiable institutional actors even where personnel, administrative structures, or physical records subsequently change. Sanctions exposure requires sensitive ownership, compliance, and payment information to be accessible to authorized reviewers without becoming publicly visible, while payment uncertainty requires milestone certifications and payment approvals to be linked to accountable decision makers. Permissioned participation therefore functions as an institutional control mechanism rather than simply as a technical restriction on network access (Govindan et al., 2024; De Matteis et al., 2025).

The framework does not require complete procurement documents or sensitive personal and commercial information to be stored directly on the ledger. Full tender files, contracts, engineering reports, ownership documentation, and other sensitive materials may remain within authorized institutional repositories, while the ledger stores authenticated references, document hashes, timestamps, approval events, responsible identities, and status changes. This separation allows later verification of documentary integrity while limiting unnecessary replication of confidential or operationally sensitive information across participating institutions (De Matteis et al., 2025).

Permissioned access must also incorporate credential lifecycle controls, including authorization, periodic review, revocation following personnel or institutional changes, and procedures for responding to compromised signing credentials (Ibrahimy et al., 2024).

4.4 Compliance integration and beneficial-ownership verification

Compliance integration is treated in this framework as part of procurement design, not as an external filter applied after award. That position is necessary because sanctions-exposed electricity procurement often involves high-value contracts, strained banking channels, uncertain beneficial-ownership structures, and pressure for rapid reconstruction. Under such conditions, ordinary procurement sequencing is insufficient (Laurendin et al., 2026). A lawful and bankable award depends on whether counterparties are properly identified, ownership chains are adequately disclosed, and payment routes can pass scrutiny. Existing literature on sanctions and energy markets shows that external restrictions and financial caution can delay energy transactions even where underlying demand is urgent and socially significant (Moteng et al., 2023; Okafor et al., 2025; Omokaro et al., 2025). Public procurement and public-sector blockchain scholarship suggest that traceability alone is insufficient where governance roles, validation steps, and accountability mechanisms remain unclear (Govindan et al., 2024; Tan et al., 2022; Ibrahimy et al., 2024).

The specific legal content of these compliance requirements will depend on the sanctions regime, procurement law, ownership-and-control rules, and financial-regulatory framework applicable to the transaction (Ibrahimy et al., 2024).

Sanctions exposure should therefore be understood as a jurisdiction-dependent compliance condition rather than a single legal category. Different regimes may vary in territorial and personal reach, designation criteria, ownership-and-control standards, sectoral restrictions, licensing or authorization procedures, reporting obligations, and enforcement consequences. Accordingly, the framework does not treat a screening result as universal “clearance.” Instead, the competent compliance function must identify the applicable legal regime and record the legal basis for any decision to permit, condition, suspend, escalate, or prohibit an award or payment (Ibrahimy et al., 2024; Laurendin et al., 2026).

The framework therefore introduces compliance as a staged institutional process. Beneficial-ownership verification comes first because the identity of the contracting party cannot be reduced to the face of the bid submission alone. Control rights, indirect ownership, intermediary structures, and affiliated entities may all affect the legal status of the transaction. A bidder should therefore move toward award only after beneficial-ownership records and control declarations have been reviewed under the applicable ownership-and-control standard and the resulting determination has been documented within the system. This step supports both procurement integrity and later payment reliability because banks and regulators require confidence in the identity and legal standing of the awardee.

Sanctions screening then follows as a second gate. Screening must address both counterparties and payment routes. This means that compliance is directed not only at the bidder and its ownership structure, but also at the channels through which payment, subcontracting, or related service delivery will occur. Ambiguous cases should not trigger immediate automated exclusion. Instead, the framework assigns them to legal and compliance review so that uncertainty can be assessed in a reasoned and documented manner. This approach reflects the wider concern in blockchain and smart contract literature that high-risk legal decisions cannot be safely reduced to automated triggers where factual ambiguity remains open (Thomas et al., 2019; Kirli et al., 2022; Santos et al., 2025).

The compliance layer thus operates as a disciplined screening structure within procurement law. It is intended to reduce award risk, strengthen payment confidence, and prevent the ledger from becoming a record of formally complete but legally unstable transactions. In this framework, beneficial-ownership and sanctions screening are therefore treated as integral components of procurement assurance within the proposed framework and not merely as procedural additions attached after the core contracting process.

Accordingly, the compliance layer should be understood as a modular governance function rather than a universal legal test. The framework identifies where ownership, sanctions, and payment-route review must occur, while the substantive criteria for clearance, licensing, prohibition, or escalation must be supplied by the competent legal and regulatory regime (Thomas et al., 2019).

4.5 Data governance, confidentiality, and rights protection

The framework treats data governance as a separate layer because record reliability does not justify unrestricted disclosure. Electricity procurement under sanctions pressure can involve ownership declarations, identity documents, banking information, technical performance records, complaints, and compliance findings (Thaldar, 2025). Some of this material must remain tightly controlled if the system is to remain lawful, credible, and acceptable to participants. A ledger that exposes sensitive information too widely may weaken participation, raise privacy concerns, and create new forms of institutional mistrust. Energy blockchain literature has increasingly recognized this issue, especially in relation to privacy preserving architectures, hybrid systems, and restricted data environments (Khorasany et al., 2021; Wang et al., 2023; Erdayandi et al., 2025).

Within the present framework, confidentiality and rights protection rest on a tiered data structure. The public-facing layer contains filtered procurement metadata suitable for publication and market awareness. The consortium governance layer contains institutionally relevant records required for contract administration, technical verification, and payment review.

Access controls should therefore operate at the level of both user roles and information categories, allowing different participants to verify the existence and integrity of a procurement event without necessarily receiving access to the underlying confidential record.

The restricted compliance environment contains beneficial-ownership material, sanctions screening results, and sensitive identity data that should be visible only to authorized users. This design is consistent with public-sector governance scholarship, which argues that accountable digital administration depends on controlled access and purpose specific disclosure rather than indiscriminate transparency (Tan et al., 2022; Ibrahimy et al., 2024; De Matteis et al., 2025).

A second element of this layer concerns correction and continuity. Procurement systems in fragile settings often suffer from incomplete files, mismatched versions, and uncertain custody. The framework responds by preserving correction history and audit continuity at the ledger level while maintaining full documentary storage in secured environments. This means that an error in a record is not silently erased. Instead, a corrected entry is linked to the earlier record in a visible sequence. This approach supports procedural fairness because later review bodies can see how the record changed, who made the correction, and at what stage it occurred. It also helps with complaint handling and payment disputes, where documentary history often matters as much as the final record itself.

Data governance in this framework is therefore directed toward lawful restraint as much as toward transparency. The aim is to maintain enough visibility for procurement integrity, while preventing unnecessary diffusion of sensitive material. In electricity procurement under sanctions exposure, controlled disclosure is part of regulatory assurance because record systems must protect both accountability and legitimate confidentiality if they are to remain usable.

4.6 Performance monitoring, incentives, and anti-collusion controls

Performance and payment assurance give the framework its operational force because procurement records become meaningful only when they are linked to contract execution, milestone verification, and release decisions. In post-conflict electricity markets, many of the most serious failures arise after award rather than at tender stage (Hou and Wang, 2026). Fuel delivery may be delayed, repair milestones may remain uncertified, payment release may stall, and disputes may emerge over whether works were completed to contract standard. A framework concerned only with award integrity would therefore remain incomplete. Studies on blockchain in energy systems suggest that record continuity, traceable events, and structured verification can improve confidence across complex transaction chains, especially where multiple parties interact at different stages of delivery and settlement (Nykyri et al., 2022; Chen et al., 2021; Lei et al., 2022).

Figure 5 shows the procurement workflow with compliance gates, milestone controls, and payment assurance. The process begins with procurement initiation and tender issue, then moves through bid receipt and evaluation, ownership verification, sanctions and payment route review, contract execution, milestone submission, engineer certification, pre-payment review, treasury approval, bank release, and final completion record. This is important because it presents procurement as a continuing sequence of legal and documentary control, rather than as a single decision at the point of award. Compliance and performance are therefore interlocked.

Table 6 supports this section by translating the workflow into ledger events and review points. It identifies what kind of record is generated at each stage, the level of automation that may be allowed, the point at which human review is mandatory, and the response where clearance is denied or a dispute arises. The table also brings anti-collusion control into the structure. Bid receipt, evaluation, ownership review, milestone certification, and pre-payment clearance all create traceable points at which irregular patterns may be detected and preserved in the record. Procurement scholarship indicates that improved traceability and documented role separation can strengthen the ability to identify suspect review patterns, unjustified approvals, and opaque payment movement (Govindan et al., 2024; Rai et al., 2024; Ibrahimy et al., 2024).

TABLE 6. Ledger event matrix for performance control and legal response.

This study therefore places performance assurance at the center of the framework. Payment is not treated as a routine administrative end point. It is treated as a regulated consequence of verified execution, preserved records, and reviewable institutional action. In that sense, performance monitoring is directly linked to bankability, credibility, and later dispute readiness.

In post-conflict procurement, this architecture is particularly relevant where contractors and financial institutions face uncertainty over whether certified work will lead to authorized payment. Linking each payment request to an attributable contract milestone, technical certification, compliance status, and financial authorization creates a reviewable chain between physical performance and payment release. The ledger does not itself guarantee payment; rather, it reduces uncertainty about whether the institutional conditions required for payment have been satisfied and documented.

4.7 Dispute resolution and bounded automation mechanisms

The final part of the framework addresses dispute resolution and bounded automation. This section is necessary because a procurement system that records events without preserving remedy pathways cannot provide real regulatory assurance (Yadav and Singh, 2026). Electricity procurement in sanctions-exposed markets may generate disputes over ownership disclosure, sanctions review, milestone validity, delayed payment, technical certification, or contract termination. Automation may assist administration, but it cannot replace legal judgment where the issue is contested, high risk, or rights affecting. The smart contract literature has repeatedly shown that automated execution is useful in rule-based settings, yet it becomes problematic where interpretation, defect, ambiguity, or contested fact must be addressed through legal reasoning (Thomas et al., 2019; Kirli et al., 2022; Santos et al., 2025).

Figure 6 presents the bounded automation and dispute escalation pathway. It separates automatable functions from matters that require human review. Time-stamping, record registration, deadline alerts, milestone calculation against preset criteria, and conditional payment file preparation may be automated because they are objective and reviewable. Sanctions match assessment, ownership ambiguity, fraud or collusion suspicion, contract termination, and disputed milestone validity are treated differently. These matters require human judgment because they can affect legal rights, contract continuity, and institutional responsibility in direct ways. This then sets out the escalation path from operational clarification to regulatory review, then to arbitration or dispute board review, and finally to court recognition or enforcement review where challenge continues.

The legal significance of this design lies in its refusal to treat automation as final authority. Table 6, discussed in the previous section, supports this principle by distinguishing automatable support functions from decision points that require mandatory human review. Public-sector blockchain governance research supports such caution because digital administration must remain accountable to reviewable authority and visible institutional responsibility (Tan et al., 2022; De Matteis et al., 2025; Ibrahimy et al., 2024). Electricity law scholarship also suggests that digital systems in regulated sectors must remain compatible with oversight and procedural fairness rather than relying on code-based closure alone (Diestelmeier, 2019; Brilliantova and Thurner, 2019; Chen et al., 2022).

The bounded automation rule therefore gives the framework its final legal safeguard. Automation may assist procurement management, but it cannot displace the right to challenge, the duty to review, or the authority of tribunals and courts. This study makes that position clear by preserving a full remedy path from administrative clarification to formal enforcement. This ensures that the procurement ledger remains useful not only during contract performance, but also when the legality or consequences of a recorded event are later disputed.

5 Discussion

The proposed framework presents a structured response to the persistent problem of weak trust and limited enforceability in electricity procurement within post-conflict and sanctions-exposed markets. The analysis in earlier sections shows that procurement failure in such environments is not mainly a technical issue, but a combined legal, institutional, and financial problem where documentation lacks authority, payment pathways remain uncertain, and dispute resolution is often delayed or ineffective. The framework responds to this condition through a layered model that connects legal recognition, governance control, compliance screening, data management, performance verification, and dispute handling into one system. This approach aligns with the broader literature which suggests that blockchain applications in energy gain meaning only when embedded within governance structures that define authority and accountability (Andoni et al., 2019; Hassan et al., 2019; Tan et al., 2022).

A central contribution of the framework lies in its treatment of blockchain records as regulated evidence rather than simple transaction logs. Existing studies often emphasize immutability and transparency, yet they give less attention to how such records can be accepted in regulatory hearings or contractual disputes (Chen et al., 2022; Jiang et al., 2025; Egunjobi et al., 2024). The present model addresses this limitation by linking ledger entries with defined record classes, authorized signers, and preserved document paths. This connection strengthens the credibility of procurement records and supports their use in verification and enforcement. The discussion therefore confirms that legal recognition is a necessary condition for any digital system intended to support procurement assurance.

The framework also highlights the importance of permissioned institutional governance. Research in energy blockchain systems often discusses decentralized participation, yet electricity procurement in fragile contexts requires identifiable actors with defined roles (Roth et al., 2022; Mollah et al., 2021; De Matteis et al., 2025). The model presented here assigns clear responsibilities to utilities, regulators, treasury bodies, engineers, and compliance units. This allocation reduces ambiguity and improves coordination across procurement stages. It also responds to concerns in public procurement literature regarding weak oversight and fragmented authority, which are often linked with corruption risk and poor contract performance (Govindan et al., 2024; Rai et al., 2024; Ibrahimy et al., 2024). The discussion suggests that blockchain can support accountability only when institutional roles are clearly defined and connected to the record system.

Another important point concerns compliance integration. Sanctions-exposed procurement requires detailed ownership verification and payment route screening, which are often treated as external checks in conventional systems. The framework integrates these elements directly into the procurement process, ensuring that contracts move forward only after identity and compliance conditions are satisfied. This design responds to findings in the sanctions literature, where financial restrictions and risk aversion can disrupt energy supply even when procurement demand is urgent (Moteng et al., 2023; Okafor et al., 2025; Omokaro et al., 2025). The discussion shows that early integration of compliance checks can reduce later disruption and improve confidence among financial actors.

Data governance is also a significant aspect of the framework. While transparency is often presented as a benefit of blockchain, unrestricted access can create new risks related to privacy and commercial sensitivity. The proposed model introduces tiered visibility, where public information is separated from restricted compliance data. This approach reflects findings in privacy focused blockchain studies, which argue that controlled disclosure is necessary in systems that handle sensitive information (Wang et al., 2023; Erdayandi et al., 2025; Zhang et al., 2026). The discussion indicates that balanced data governance is required to maintain both accountability and participation.

Performance monitoring and payment assurance represent another key contribution. The framework connects contract execution, milestone verification, and payment release within a single record structure. This connection reduces uncertainty and supports timely financial flows. Studies in energy systems suggest that traceable and time-stamped records can improve coordination and reduce disputes across transaction chains (Nykyri et al., 2022; Chen et al., 2021; Lei et al., 2022). The discussion confirms that linking performance records with payment conditions strengthens procurement reliability in high-risk environments.

The final element of the discussion concerns dispute readiness and bounded automation. The framework limits automation to objective tasks while reserving complex decisions for human review. This approach reflects concerns in smart contract research, where automated execution may create problems when legal interpretation or factual uncertainty is involved (Thomas et al., 2019; Kirli et al., 2022; Santos et al., 2025). The model ensures that all actions remain reviewable and that disputes can move through defined escalation pathways. This design supports legal accountability and preserves procedural fairness.

5.1 Why a permissioned distributed ledger?

The proposed framework does not assume that blockchain is inherently superior to conventional database architectures. A centralized digitally signed database may provide strong integrity controls, lower implementation complexity, higher transaction throughput, and simpler privacy management where a single institution is sufficiently trusted to administer the authoritative record. A federated or replicated database can further distribute availability and institutional access while retaining comparatively mature data-management and governance mechanisms. These alternatives may therefore be preferable where institutional authority is stable, responsibility for the authoritative record is uncontested, and participating organizations are willing to rely on a common administrator (Ibrahimy et al., 2024; Omokaro et al., 2025).

A permissioned distributed ledger becomes more relevant under the narrower conditions addressed by this study: multiple legally distinct institutions must contribute to and verify a shared procurement history, no single participant is an uncontested custodian of the complete record, institutional fragmentation creates risks of inconsistent or retrospectively altered records, and later verification of the sequence and attribution of decisions is important. Under these conditions, replicated validation and tamper-evident event histories can reduce dependence on a single record administrator. These benefits nevertheless involve trade-offs, including greater governance complexity, implementation and coordination costs, scalability constraints, key-management requirements, and continuing privacy concerns. The framework therefore treats blockchain as a conditional architectural choice rather than a universal requirement for public procurement (Wang et al., 2023; Moteng et al., 2023).

The comparison is qualitative and conceptual; relative cost, performance, resilience, and privacy outcomes would depend on the specific technologies and institutional configuration selected for implementation.

Table 7 demonstrates that the justification for a permissioned distributed ledger is institutional rather than technological. If a trusted public authority can reliably maintain a digitally signed centralized database and all relevant participants accept that authority, blockchain may add unnecessary cost and complexity. The distributed-ledger option becomes more defensible when procurement governance is institutionally fragmented and several independent actors require a common, attributable, and tamper-evident transaction history without transferring exclusive control of that history to one participant.

TABLE 7. Comparative suitability of alternative record architectures.

This conditional approach is consistent with public-sector blockchain research cautioning that distributed ledgers do not necessarily provide clear advantages over conventional digital record-keeping systems in every governmental application (Bustamante et al., 2022).

5.2 Failure modes and governance safeguards

The use of a permissioned distributed ledger does not eliminate the reliability risks associated with procurement information or institutional behavior. Immutability protects the integrity of recorded events after validation, but it cannot establish that the underlying information was accurate when submitted. The framework must therefore distinguish record integrity from substantive truth. This distinction is consistent with records-management scholarship cautioning that blockchain-based immutability does not by itself establish the authenticity, reliability, or evidentiary quality of the information initially recorded (Lemieux, 2016). False certification, inaccurate ownership information, collusive approval, or fraudulent supporting documents can produce an immutable but unreliable record if upstream verification fails. Regulatory assurance consequently depends on institutional verification, segregation of duties, accountable validation, and subsequent review in addition to cryptographic integrity (De Matteis et al., 2025).

These concerns are consistent with broader blockchain-governance research showing that trustworthy operation depends not only on technical mechanisms but also on governance arrangements for decision-making, coordination, accountability, and system evolution (Liu et al., 2022).

These safeguards also demonstrate why the ledger cannot replace institutional governance. Technical controls can make unauthorized alteration more difficult and improve attribution, but they cannot independently resolve fraudulent input, institutional collusion, compromised credentials, conflicting legal interpretations, or disputes over authority. The framework therefore requires technological assurance to operate alongside conventional procurement controls, professional judgment, legal oversight, cybersecurity governance, and business-continuity procedures.

Because ledger integrity cannot compensate for loss of the underlying off-chain evidence, authorized repositories must also maintain appropriate retention, redundancy, backup, and recovery arrangements.

5.3 Scenario-based conceptual validation

Because the proposed framework has not yet been implemented in an operational procurement environment, its validation at this stage is conceptual rather than empirical. To assess internal coherence and practical coverage, the six-layer architecture can be applied to a hypothetical post-conflict electricity procurement scenario involving the urgent acquisition of grid-rehabilitation equipment from an international supplier under sanctions exposure, fragmented institutional authority, and externally financed payment arrangements. The scenario is used as an analytical stress test to examine whether the framework provides identifiable governance mechanisms for the principal legal, institutional, compliance, information, performance, payment, and dispute risks identified in the preceding analysis (De Matteis et al., 2025; Okafor et al., 2025).

The scenario indicates that each major procurement vulnerability identified in the study can be mapped to at least one framework function and that several high-risk events require interaction among multiple layers. For example, payment authorization depends not only on performance certification but also on institutional authority and the applicable compliance determination, while a later dispute may require evidence generated across the legal, governance, compliance, data, and performance layers. This cross-layer dependence supports the internal coherence of the architecture but should not be interpreted as evidence of real-world effectiveness. The exercise demonstrates conceptual coverage and identifies where implementation testing is required.

The scenario-based assessment provides only conceptual validation and cannot establish implementation feasibility, institutional acceptance, legal effectiveness, cost efficiency, cybersecurity performance, or procurement outcomes. These dimensions require subsequent empirical investigation using expert evaluation, jurisdiction-specific legal mapping, prototype testing, and comparative case studies.

The principal governance safeguards and the corresponding scenario-based conceptual assessment are summarized in Tables 8, 9. For illustration, implementation within an EU-regulated procurement environment would require the framework’s legal-recognition, data-governance, procurement, and compliance layers to operate consistently with the relevant categories of EU legal instruments. These include Regulation (EU) No 910/2014 on electronic identification and trust services for electronic transactions (eIDAS), as amended by Regulation (EU) 2024/1183; Regulation (EU) 2016/679 (General Data Protection Regulation—GDPR) for personal-data processing and protection; Directive 2014/24/EU and, where applicable to utility-sector procurement, Directive 2014/25/EU for public procurement; and the applicable EU restrictive-measures regulations governing sanctions exposure (European Parliament and Council of the European Union, 2014a; European Parliament and Council of the European Union, 2014b; European Parliament and Council of the European Union, 2014c; European Parliament and Council of the European Union, 2016; European Parliament and Council of the European Union, 2024). These instruments illustrate that blockchain-based records and automated controls must operate within the applicable legal framework rather than independently determining legal validity, procurement eligibility, or sanctions compliance.

TABLE 8. Key failure modes and governance safeguards.

TABLE 9. Scenario-based validation of the proposed framework.

6 Conclusion

This study set out to address a clear gap in the existing literature, which has given strong attention to blockchain applications in energy systems while giving limited consideration to how such systems can achieve legal recognition and regulatory assurance in sanctions-exposed electricity procurement. The aim of the study was to develop a legal and institutional framework through which blockchain-based records can support legally reviewable procurement and regulatory processes. The study responds to this gap by proposing a structured model that connects ledger records with governance rules, compliance processes, and dispute mechanisms. The major conclusions of the study can be summarized as follows.

• The effectiveness of blockchain in electricity procurement depends on legal recognition of ledger records as admissible and reviewable evidence within regulatory and contractual systems
• Permissioned institutional governance is necessary to assign responsibility, control access, and maintain accountability across procurement stages
• Compliance integration, including beneficial-ownership verification and sanctions screening, must be embedded within procurement workflows to reduce financial and legal risk
• Data governance requires a tiered visibility structure that protects sensitive information while maintaining sufficient transparency for accountability
• Performance assurance and dispute readiness depend on linking milestone verification, payment control, and review pathways within a continuous and auditable record system

Finally, this study has some limitations that should be acknowledged. In particular, questions of evidentiary status, procurement validity, and court recognition depend on the legal rules of specific jurisdictions, so the framework should not be read as automatically reflecting current law in any one country. Additionally, the framework is conceptual and based on doctrinal and analytical reasoning rather than empirical testing in a specific country context. Differences in legal systems, institutional capacity, and sanctions regimes may affect how the framework can be applied in practice. Future research may focus on case-based validation, pilot implementation in selected electricity markets, and comparative analysis across different post-conflict environments. Further work may also examine how financial institutions respond to such systems and how regulatory bodies can adapt existing laws to support ledger-based evidence.

Because the framework is technology-neutral at the conceptual level, it does not prescribe a specific distributed-ledger platform or consensus protocol. Platform selection would require jurisdiction- and implementation-specific assessment of institutional participation, interoperability, security, scalability, data-residency requirements, and operational capacity.

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Footnotes

Edited by: Horst Treiblmaier, MODUL University Vienna, Austria

Reviewed by: Sokratis Vavilis, Inlecom Innovation, Greece

Javad Farahani, MODUL University Vienna, Austria

Tamara Saad Mohamed, University of Kut, Iraq