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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
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.
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.
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"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
(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), and by the FTC in the U.S. regarding adequacy of consumer disclosures for products with significant financial risk. The provision constitutes a material risk disclosure that regulators may evaluate for adequacy and prominence. (2) GOVERNANCE EXPOSURE: Medium. The provision clearly discloses the non-custodial nature of the Ledger device and the permanence of recovery phrase loss, which is consistent with industry practice for hardware wallet products. However, the adequacy of this disclosure as a standalone risk mitigation tool may be evaluated by regulators in jurisdictions introducing crypto asset consumer protection requirements. (3) JURISDICTION FLAGS: EU consumers under MiCA may have access to additional protections or disclosure requirements as that regulation is implemented. In the U.S., the FTC has jurisdiction over adequacy of consumer disclosures for products marketed to manage financial assets. UK Financial Conduct Authority may have jurisdiction depending on how Ledger products are classified under evolving crypto asset regulation. (4) CONTRACT AND VENDOR IMPLICATIONS: Institutional purchasers deploying Ledger devices for employee or client use should note that this provision places full recovery phrase custodial responsibility on the end user, with no contractual recovery option from Ledger. Enterprise procurement and security policies should account for this operational dependency. (5) COMPLIANCE CONSIDERATIONS: The prominence and clarity of this disclosure should be reviewed against applicable consumer protection disclosure requirements in target markets. Internal security training and onboarding materials for institutional deployments should reflect the terms of this provision.
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Provision-level monitoring, governance timelines, and regulatory mapping built from archived source documents and historical version tracking.
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.
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.
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