
28 May Futureproofing Human Rights Symposium: Human Rights in the Era of Blockchain – A Polycentric Accountability Framework
[Gustavo Prieto works for the Research Foundation Flanders (FWO) and is Senior Fellow and Lecturer at the Law Faculty of Ghent University, Belgium]
Blockchain technology, with its decentralized and global reach, is transforming how rules, authority, and accountability are understood. Far from being confined to cryptocurrency payments, blockchain is rapidly shaping key arenas such as digital identities, supply chains, and the energy sector. These developments provoke a deeper question: How can a decentralized, code-based system be compatible with longstanding legal frameworks—particularly international human rights law?
Like a double-edged sword, blockchain has the potential to enhance accountability of other actors, but it can also undermine oversight by dispersing responsibility and making harmful actions harder to trace. Its decentralized nature opens up innovative possibilities for transparency and distributed verification, yet this same infrastructure could complicate the traceability of unlawful activities, allowing some actions to bypass existing accountability frameworks. This dual nature makes blockchain a compelling case for exploring how human rights accountability can operate in polycentric systems, where authority and responsibility are shared across multiple, overlapping actors.
Here, I briefly examine how human rights accountability can be carried out within polycentric systems, as the tension between enabling new forms of accountability and disrupting existing ones underscores the need for new conceptual tools. One promising approach is to develop public-private convergence frameworks—collaborative structures that bring together regulators, standard-setters, and private actors to coordinate rules, oversight, and enforcement. Embedding human rights standards into these models helps ensure that accountability becomes a core element of decentralized systems, rather than a secondary concern.
Blockchain, Human Rights, and the Rethinking of Accountability
To fully grasp the relevance of blockchain to human rights, it helps to begin by clarifying what blockchain technology fundamentally is: a decentralized digital infrastructure maintained by multiple independent actors rather than a single centralized authority (see further explanation here).
The connection to human rights emerges because blockchain infrastructures increasingly provide services beyond financial services—such as digital identity management, aid distribution, and secure data storage—that function as public goods, historically governed or regulated by centralized entities, such as governments or international organizations.
Human rights governance already exhibits elements of decentralization: while states traditionally hold primary responsibility, actors like NGOs, corporations, and international organizations also play crucial roles. Yet key functions such as standard-setting and decision-making still follow a predominantly top-down logic, driven by states and international judicial or quasi-judicial bodies. This creates a system where decentralized participation coexists with hierarchical authority .
There are several new developments of blockchain infrastructures that illustrate the relation between human rights accountability and blockchain nature. For instance, projects like the UN World Food Programme’s Building Blocks sought to enhance refugee aid distribution, while digital identity initiatives attempted to provide secure identities for stateless individuals (here, here). These efforts aimed to support human rights accountability by promising individuals more control over their data. However, their actual impact remains contested. In practice, these systems often introduced rigid models of implementation that were designed without meaningful participation from the communities they intended to serve. As a result, while presented as rights-enhancing, such initiatives could unwittingly be reinforcing top-down approaches.
These examples show that blockchain initiatives simultaneously support and challenge human rights accountability. This tension between enabling new forms of accountability and disrupting existing ones highlights the need for new conceptual tools. Given this duality, traditional centralized frameworks may not fully capture blockchain’s unique governance dynamics. Therefore, adopting insights from theories of polycentric governance can help us better understand—and critically evaluate—the layered, overlapping models of accountability emerging from decentralized blockchain systems
The Polycentric Nature of Blockchain
Polycentricity, a concept first popularized by Michael Polanyi in The Logic of Liberty (1951), describes social systems composed of multiple decision-making centers where no single authority holds absolute control. Each center operates according to local rules but is also interdependent with others. While this might sound chaotic, Polanyi argued that such arrangements can self-organize and innovate—provided there are suitable mechanisms for “mutual adjustment” among the various participants.
Blockchain technology exemplifies polycentricity. In a “public permissionless” blockchain, for instance, data is stored and validated by countless nodes distributed across various jurisdictions. Decision-making is decentralized, guided not by a central authority but by consensus rules encoded in software. Participants are spread across the world and include developers, investors, regulators, and enthusiasts. Multiple “centers” coexist, each playing a role in shaping how the infrastructure evolves.
Coordinating tasks across multiple centers is inherently challenging, especially in the absence of a centralized authority or binding legal framework. Such a decentralized setup disrupts traditional legal frameworks, which have historically relied on centralized points of enforcement—be it the nation-state or a powerful economic actor such as multinational corporations. In contrast, blockchain communities tend to reject hierarchical control. This makes accountability, particularly human rights accountability, even more critical.
Thus, understanding how blockchain governance navigates these complexities also holds value for human rights accountability beyond digital infrastructures. The lessons learned could help identify new approaches to accountability in human rights governance. In practice, blockchain networks use mechanisms to maintain trust despite their decentralized nature. Similarly, human rights governance exhibits some polycentric characteristics, with multiple actors contributing to accountability. Given this parallel, innovations in blockchain governance such as decentralized monitoring systems and peer-to-peer validation may offer valuable insights for strengthening human rights accountability.
Towards a Public-Private Framework for Blockchain Accountability
Given this complexity, a pressing question is how the polycentric nature of blockchain—characterized by dispersed authority and overlapping actors—mirrors the challenges found in human rights implementation. In that sense, how can we draw lessons from blockchain governance to strengthen accountability in similarly decentralized human rights frameworks?
A promising analogy comes from what scholars and regulators have termed the “Global Financial Architecture.” This framework emerged in response to the 2007–2009 global financial crisis, spurred on by the G-20, which recognized that financial stability (here, here) in an interconnected world required coordination and standard-setting beyond any single country or organization.
Within this architecture, the Financial Stability Board (FSB) stands out as a compelling example of a public-private convergence body, embodying the essence of polycentric governance. The FSB brings together regulators, standard-setting organizations, and private sector representatives to harmonize global standards, coordinate regulatory efforts, and oversee their implementation. Unlike traditional treaty-based institutions, the FSB derives its legitimacy from high-level political endorsements, such as those from the G-20, and support from the UN General Assembly.
This flexible yet influential governance model demonstrates how decentralized coordination can be both effective and legitimate. Similarly, blockchain’s polycentric nature presents an opportunity to rethink accountability structures in the human rights field, fostering more dynamic and inclusive approaches to global governance.
Rethinking Human Rights Oversight
Blockchain developments—ranging from cryptocurrency markets to smart contracts—cut across borders and regulatory domains much like global finance. No single national legislature can comprehensively oversee all aspects of blockchain’s development. Instead, multiple standard-setting and regulatory bodies must converge within an institution that holds international recognition and legitimacy. An explicit mandate, either through the G-20 or the UN General Assembly, could formally acknowledge the global nature of blockchain and establish consistent accountability standards.
A public-private convergence body, functioning similarly to the Financial Stability Board, could coordinate “soft law” rules among standard-setting organizations such as the International Organization for Standardization (ISO) and the Institute of Electrical and Electronics Engineers (IEEE), alongside regulators and industry stakeholders.
Additionally, such a body could administer polycentric tasks, overseeing dispute resolution mechanisms, audits, and transparency measures across jurisdictions to ensure accountability in decentralized systems. Though still largely a conceptual proposal, this approach draws inspiration from real-world frameworks that already bring together public and private actors. Embracing a public-private model acknowledges that decentralized digital systems cannot be effectively governed through top-down state intervention or private self-regulation alone.
Embedding Human Rights in Decentralized Governance
If blockchain governance requires new institutional models to ensure accountability, the same holds true for human rights. Historically, human rights law was designed to hold centralized entities—primarily states—accountable for violations against individuals. But blockchain challenges this premise: it disperses authority, embeds decisions in code, and blurs the lines of legal responsibility. In this context, human rights protection must also evolve to operate within polycentric systems.
Just as financial and technical regulation is moving toward convergence frameworks, human rights norms must be embedded in the emerging institutions that govern blockchain. This means treating human rights not as an external concern but as a core feature of governance design. Public-private convergence bodies could take on this role by facilitating collaboration between developers, regulators, and human rights institutions to ensure that rights protections are integrated into both the architecture and oversight of blockchain systems.
This approach builds on existing regulatory logics while expanding their scope. For instance, integrating human rights criteria into standard-setting processes—such as those led by ISO or IEEE—can ensure that privacy, security, and non-discrimination are considered from the ground up. Likewise, convergence forums can open space for dialogue between legal and technical communities, aligning accountability mechanisms with human rights values.
Rather than viewing blockchain as a threat to human rights, this model presents it as an opportunity to reimagine how accountability can function in distributed systems. Embedding human rights standards into governance frameworks is not only a normative imperative—it is increasingly recognized by developers as essential to the technology’s legitimacy (see here).
As concerns around ethical design and long-term trust grow, integrating clear rights protections has become both a practical and strategic priority. Trust is central to blockchain’s broader adoption, and visibly incorporating human rights into its design and oversight can help foster that trust. When users, regulators, and investors see these standards taken seriously, they are more likely to support blockchain innovations. Conversely, neglecting such safeguards risks regulatory backlash and public distrust, threatening the very decentralization blockchain aims to protect
A Glimpse into the Future of Human Rights in Code-Based Systems
Blockchain technology provides a fascinating test case for how accountability can be upheld in a system that, by design, disperses power and authority across numerous actors and networks. The concept of ‘polycentricity’ highlights the complexity and novelty of this challenge: coordinating tasks in an environment with no central arbiter for resolving disputes and enforcing standards. Yet the need for a new accountability model is urgent, as blockchain is already transforming financial markets, identity systems, and other critical areas.
The insights gained from blockchain governance and its polycentric accountability challenges extend beyond digital systems and offer valuable lessons for other polycentric regulatory environments, such as climate change governance. Both operate without a singular governing authority, relying instead on a web of institutions, regulatory bodies, and private actors.
Thus, the challenge in all these systems lies in balancing autonomy with accountability and aligning diverse interests under a shared framework of responsibility. The concept of a public-private convergence framework, as proposed here for blockchain, could well serve as a model for improving accountability in financial and environmental governance while embedding human rights and sustainability principles into their foundational structures.
Author’s notes: This post builds on research in Gustavo Prieto, ‘International Human Rights Law in the Era of Blockchain: Redefining Accountability in Decentralized Systems’ in Irene Couzigou (ed.), International Law and Technological Change: Testing the Adaptability of International Law (Edward Elgar, forthcoming 2025)
The text was written during a Research Foundation – Flanders fellowship (FWO.3E0.2022.0079.01) at Ghent University. The views expressed are solely the author’s and do not represent those of the institutions mentioned.
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