Bird & Bird advises on European Blockchain Sandbox report

Bird & Bird and its consulting arm OXYGY, together with the European Commission, have published the 3rd and final cohort best practices report. The dialogues for the cohort took place in the second half of 2025, and the report highlights the lessons learned, best practices and recommendations.

The publication of the final cohort report marks a significant milestone for the European Blockchain Sandbox – concluding the successful completion of 20 cross-border regulatory dialogues between innovators, regulators and legislators per annum, from 2023 until 2026. The use cases selected for the 3 Sandbox cohorts span blockchain/DLT, and other innovative technologies (e.g. AI, IoT, cloud computing) which are often deployed in combination.

A broad range of regulatory areas were covered during the dialogues, ranging from data protection/data regulation, cyber security and the AI Act to financial sector regulation including regulation of crypto assets and token projects spanning multiple industries.

The European Blockchain Sandbox reinforces the value of regulatory sandboxes for providers of emerging technologies facing legal uncertainty around evolving regulations. By convening real world use cases, national authorities, and EU legislators and regulators in a single ecosystem, a regulatory sandbox clarifies how different regulatory regimes interact and strengthens legal certainty to support innovation.

Marjolein Geus (pictured), partner at Bird & Bird, commented: “By bringing innovators, national regulatory authorities, and EU regulators together with legal/regulatory specialists in a single, informal/confidential cross-border setting, with the objective to not only identifying regulatory challenges but also solutions to overcome these challenges, the Sandbox has supported efficient and effective compliance, making use of EU wide regulatory instruments in support of innovation. We hope these insights will enhance robust and efficient compliance, inform future policy and help innovators scale with confidence.”

The 3rd best practices report was launched with a supporting public webinar on the 11th Feb, in which the Sandbox team shared an overview of the regulatory best practices identified in cohort 3, and answered questions from the audience.

The Sandbox context

The European Blockchain Sandbox was an initiative of the European Commission which aimed to establish a pan-European framework for regulatory dialogues. The goal of the sandbox was to enhance legal certainty around blockchain/DLT applications, in support of a robust regulatory framework across the EU/EEA for this emerging area of technology. Initiated through an open call for tenders in 2022, the sandbox was facilitated by a consortium under the lead of Bird & Bird with its consulting arm OXYGY, and blockchain experts from Warren Brandeis.

Use case selection was validated by an independent panel of academic experts (Professor Roman Beck, Professor Soulla Louca, and Professor Walter Blocher) and IT set up was supported by Spindox. The consortium managed the set up and facilitation of 3 separate sandbox cohorts over 3 years from 2023 – 2026: through a rigorous application and selection process for blockchain/DLT use cases, to onboarding of relevant regulators/authorities, to facilitating the dialogue meetings and capturing a wealth of best practices.

The best practices and lessons learned, which are relevant for the entire blockchain/DLT community across the EU/EEA, were captured in reports for each cohort.