Provision record
Ledger · Ledger Terms of Sale · View original document ↗

Recovery Phrase Liability Disclaimer

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Document Record

What it is

The document states that Ledger holds no backup copies of the user's 24-word recovery phrase, and that loss or disclosure of the phrase may result in permanent loss of access to crypto assets or their misappropriation by any party who obtains the phrase. The user bears sole responsibility for securing the recovery phrase.

This analysis describes what Ledger's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision establishes that the user bears sole custodial responsibility for the recovery phrase, with no recovery mechanism available from Ledger. This clause is operationally significant for users of Ledger hardware wallets because loss of the recovery phrase results in irreversible loss of access to associated crypto assets according to the document.

Clause Stability Stable

0
Changes
5
Months Monitored
Jul 9, 2026
First Seen
Jul 9, 2026
Last Seen

Consumer impact (what this means for users)

Under this provision, the agreement establishes that Ledger retains no backup of the 24-word recovery phrase, and that loss or unauthorized disclosure of the phrase may result in permanent inability to access associated crypto assets. The agreement places full responsibility for recovery phrase security on the purchaser.

Cross-platform context

See how other platforms handle Recovery Phrase Liability Disclaimer and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
For security reasons, Ledger does not hold any backup copies of your 24 words; You may no longer be able to access your crypto assets – permanently; You run the risk that anyone (in possession of your 24 words) will be able to access your crypto assets in order to misappropriate them and associate them with their own private key.

Excerpt from Ledger's Terms of Sale

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision may engage financial consumer protection frameworks in jurisdictions where crypto asset custody services are regulated, including potential oversight by financial regulators in the EU under MiCA (Markets in Crypto-Assets Regulation), …

Insight

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Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →

Provision details

Document information
Document
Ledger Terms of Sale
Entity
Ledger
Document last updated
May 5, 2026
Tracking information
First tracked
April 27, 2026
Last verified
July 9, 2026
Record ID
CA-P-015112
Document ID
CA-D-00277
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
5761b01ad9251bf4b490971d3c0a1270c63953747ebdbce5a44bea93d43fa0b2
Analysis generated
April 27, 2026 15:28 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Ledger
Document: Ledger Terms of Sale
Record ID: CA-P-015112
Captured: 2026-04-27 15:28:36 UTC
SHA-256: 5761b01ad9251bf4…
URL: https://conductatlas.com/platform/ledger/ledger-terms-of-sale/provision/CA-P-015112/recovery-phrase-liability-disclaimer/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Ledger's Recovery Phrase Liability Disclaimer clause do?

This provision establishes that the user bears sole custodial responsibility for the recovery phrase, with no recovery mechanism available from Ledger. This clause is operationally significant for users of Ledger hardware wallets because loss of the recovery phrase results in irreversible loss of access to associated crypto assets according to the document.

How does this clause affect you?

Under this provision, the agreement establishes that Ledger retains no backup of the 24-word recovery phrase, and that loss or unauthorized disclosure of the phrase may result in permanent inability to access associated crypto assets. The agreement places full responsibility for recovery phrase security on the purchaser.

Is ConductAtlas affiliated with Ledger?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Ledger.