Taking security over GPUs, country by country.

Usual security

Fixed and floating charges, usually in a debenture

Register

Companies House

Deadline

21 days

• RegistrationStatute

  Companies House registers a charge if a statement of particulars is delivered within the period allowed. That period is 21 days beginning with the day after the charge is created. Where the charge is in an instrument, a certified copy must go with it.

  Companies Act 2006, s859A
• If it is missedStatute

  An unregistered charge is void against a liquidator, an administrator and any creditor of the company, so far as it gives security over the company's property. The secured money becomes immediately payable.

  Companies Act 2006, s859H
• How the filed deals do itFiled deal

  The Nscale Europe GPU facility takes an English law debenture from the borrower and its subsidiary guarantors, alongside local law security in each country where GPUs sit.

  Nscale Europe GPU credit agreement, Nscale S-1 Ex 10.14

On the regulatory trackerNational Security and Investment Act 2021Data centres designated critical national infrastructure

Usual security

Fixed and floating charges, usually in a debenture

Register

Companies Registration Office (CRO)

Deadline

21 days

• RegistrationStatute

  A charge is void against the liquidator and any creditor unless the prescribed particulars reach the Registrar within 21 days of its creation. The alternative is a two-stage filing: a notice of intention, then a notice that the charge has been created within 21 days of the first.

  Companies Act 2014, s409 (as enacted)
• If it is missedStatute

  The charge is void against the liquidator and creditors, but the obligation to repay is not affected, and the money secured becomes immediately payable. A filing that leaves out a property voids the charge over that property only.

  Companies Act 2014, s409 (as enacted)
• What is outside the regimeStatute

  Charges over cash, bank deposits, shares, bonds and other financial instruments, and the rights attached to them, are excluded from the definition of a charge. A charge over servers and other equipment is within it.

  Companies Act 2014, s408 (as enacted)
• The registerStatute

  The Registrar keeps a register of charges for each company, recording the date and time each filing was received, short particulars of the property charged and the persons entitled. Anyone may inspect it.

  Companies Act 2014, s414 (as enacted)

On the regulatory trackerCRU connection policy for data centresNIS2 Directive

Usual security

Undisclosed pledge (stil pandrecht) over movables

Register

No public register; a notarial deed, or a private deed registered with the Belastingdienst

Deadline

No fixed deadline; the pledge exists from the notarial deed or the registration

• How it is createdStatute

  A pledge over movables can be created by a notarial deed or a registered private deed, without the goods passing into the lender's control. The pledgor must declare in the deed that it may pledge the goods and what other rights, if any, burden them.

  Burgerlijk Wetboek Boek 3, art. 3:237
• On defaultStatute

  If the pledgor or debtor defaults, or gives good reason to fear it will, the lender can demand that the goods be brought under its control or a third party's.

  Burgerlijk Wetboek Boek 3, art. 3:237
• No security transferStatute

  A transfer of title intended as security is not a valid basis for a transfer. Dutch security over servers is therefore a pledge, not the German-style transfer of ownership.

  Burgerlijk Wetboek Boek 3, art. 3:84(3)
• Why the deed is registeredOfficial guidance

  The government's explanatory memorandum says registration matters for pledges because the existence of a non-possessory pledge on a given date must be provable against third parties. Registration of private deeds stays with the Belastingdienst.

  Explanatory memorandum, Kamerstukken 33406 no. 3
• In bankruptcyStatute

  Pledgees can exercise their rights as if there were no bankruptcy. The supervisory judge can declare a cooling-off period of up to two months, extendable once by up to two months, during which enforcement needs the judge's permission.

  Faillissementswet, art. 57Faillissementswet, art. 63a
• The tax collector's floor rightStatute

  For some taxes, including wage tax and VAT, third parties cannot object to the collector's seizure of goods on the taxpayer's premises that furnish the premises or serve the use of the land ('floor goods'). A pledgee must tell the collector before it enforces against such goods. Whether servers in a data hall are floor goods is a point to settle with local counsel.

  Invorderingswet 1990, art. 22Invorderingswet 1990, art. 22bis

On the regulatory trackerNIS2 DirectiveEU data centre energy reporting and rating scheme

Usual security

Security transfer of ownership (Sicherungsübereignung)

Register

No register

Deadline

None; the transfer takes effect on agreement

• How it is createdStatute

  Ownership of a movable passes by agreement and delivery. Where the owner keeps possession, delivery can be replaced by agreeing a legal relationship that gives the lender indirect possession. That is how a borrower keeps running servers it has transferred to the lender as security.

  BGB § 929BGB § 930
• Why not a pledgeStatute

  A pledge of movables needs the goods to be handed to the creditor, and it ends if the creditor returns them to the pledgor. A pledge does not work for equipment the borrower must keep using.

  BGB § 1205BGB § 1253
• In insolvencyStatute

  A creditor to whom the debtor transferred a movable as security has a right to separate satisfaction, like a pledgee. It does not get the asset back outright: the administrator may sell movables in its possession.

  InsO § 51InsO § 166
• The insolvency cost deductionStatute

  When the administrator sells, the estate first takes a flat 4% of proceeds for determining the asset and the rights in it and, as a rule, 5% for realisation, plus any VAT. This is a fixed haircut to model in a German GPU facility.

  InsO § 170InsO § 171
• The landlord's lienStatute

  A landlord has a statutory lien over the tenant's own items brought onto the premises, for claims under the lease, and it applies to commercial premises. The lien ends when the items are removed, unless removal is without the landlord's knowledge or over its objection. Lenders therefore ask the data centre landlord for a waiver or an access letter.

  BGB § 562BGB § 562aBGB § 578

On the regulatory trackerEnergy Efficiency Act: data centre dutiesNIS2 Directive

Usual security

Non-possessory pledge (gage sans dépossession)

Register

Registre des sûretés mobilières, at the commercial court registry

Deadline

Not verified

• Where it is registeredOfficial guidance

  The registry lists non-possessory pledges among the security it registers, except pledges over registered motor vehicles under the second paragraph of article 2338 of the Civil Code. The clerk checks each filing against the deed and issues certified statements of registered pledges to anyone who asks.

  Greffe du Tribunal des activités économiques de Paris, informations sur les sûretés mobilières
• Which registryOfficial guidance

  The filing goes to the registry of the court where the grantor (or the owner of the pledged asset, if different) has its main registration on the trade and companies register. If there is none in France, it goes to Paris.

  Greffe du Tribunal des activités économiques de Paris, informations sur les sûretés mobilières
• Statute textNot verified

  Légifrance refused our automated checks, so the Civil Code articles on the pledge (from article 2333) are not quoted here. Any filing deadline and the ranking rules are not stated.

On the regulatory trackerNIS2 DirectiveEU data centre energy reporting and rating scheme

Usual security

UCC Article 9 security interest under a security agreement

Register

State filing office (UCC-1)

Deadline

No fixed deadline; priority generally runs from filing

• PerfectionStatute

  A financing statement must be filed to perfect a security interest, subject to the exceptions in § 9-310(b) and § 9-312(b).

  UCC § 9-310
• Where to fileStatute

  Perfection is governed by the law of the place where the debtor is located. A registered organisation, such as a Delaware LLC, is located in the state under whose law it is organised. So the filing follows the borrower's state of formation, not the state where the data hall is.

  UCC § 9-301UCC § 9-307
• Fixtures riskStatute

  Where equipment becomes a fixture, the security interest is subordinate to a conflicting interest of an owner or encumbrancer of the real property other than the debtor, unless one of the exceptions in § 9-334(d) to (h) applies. This is why lenders want servers to stay removable personal property and ask for landlord waivers.

  UCC § 9-334
• How the filed deals do itFiled deal

  Nscale Ward County requires a list of GPU serial numbers within 60 days. CoreWeave DDTL 5.5 requires data centre access and step-in letters within 120 days.

  Nscale Ward County GPU credit agreement, Nscale S-1 Ex 10.23CoreWeave DDTL 5.5 credit agreement, Ex 10.1

On the regulatory trackerUS export controls on advanced AI chipsData Center Validated End User authorisation

Usual security

Pledge over operating assets (pant i driftstilbehør)

Register

Løsøreregisteret (Brønnøysund)

Deadline

No fixed deadline; protection runs from registration

• What it coversReference work

  Only businesses can pledge operating assets. The pledge covers the assets as they are at any time. The owner may replace assets in line with proper operation of the business, and items disposed of fall out of the pledge.

  Store norske leksikon, «tilbehørspant»
• PerfectionReference work

  Protection against third parties (rettsvern) comes from registration in the owner's name in Løsøreregisteret. The rules sit in sections 3-4 to 3-10 of the Mortgages Act (panteloven).

  Store norske leksikon, «tilbehørspant»
• The registry formOfficial guidance

  The official pledge form offers two choices: all of the pledgor's operating assets under section 3-4, or all assets of an operationally separate part of the business.

  Brønnøysundregistrene, panterett for pant i driftstilbehør (form, July 2026)
• How the filed deals do itFiled deal

  Nscale Europe's Norwegian security includes floating charges over operating assets (driftstilbehør), trade receivables (factoringpant) and inventory (varelager) of each Norwegian guarantor.

  Nscale Europe GPU credit agreement, Nscale S-1 Ex 10.14
• Statute textNot verified

  We could not retrieve panteloven from Lovdata to check the sections directly. The points above rest on the reference work and the registry's own form.

Usual security

Business mortgage (företagshypotek)

Register

Företagsinteckningsregistret (national register)

Deadline

No fixed deadline; registered in a fixed amount

• How it is createdStatute

  A business that wants to grant a business mortgage can have a set amount registered against the business (företagsinteckning). The evidence of registration is a business mortgage certificate (företagsinteckningsbrev).

  Lag (2008:990) om företagshypotek
• What it coversStatute

  It covers the business's movable property that belongs to the mortgaged business. It does not cover cash and bank balances, listed shares and other financial instruments, property that can be mortgaged by its own registration, or property that cannot be attached or enter bankruptcy.

  Lag (2008:990) om företagshypotek
• RankingStatute

  Priority in movable property belonging to the business follows the business mortgage (section 5 of the Rights of Priority Act). That is a special priority right, which under section 15 ranks ahead of general priority rights, subject to a limited exception for certain general priority claims.

  Förmånsrättslag (1970:979), 5 §
• RegisterStatute

  Registrations are kept in a single national business mortgage register, run by an authority the government designates.

  Lag (2008:990) om företagshypotek

Usual security

Enterprise mortgage (yrityskiinnitys)

Register

Finnish Patent and Registration Office (PRH)

Deadline

No fixed deadline; valid until removed

• What it coversOfficial guidance

  An enterprise mortgage covers all the business's movable fixed, current and liquid assets. It does not cover property that can be registered under other laws, such as ships and aircraft.

  Finnish Patent and Registration Office (PRH), enterprise mortgages
• Running the businessOfficial guidance

  The business keeps the assets and can sell them in the ordinary course. New assets fall under the mortgage automatically.

  Finnish Patent and Registration Office (PRH), enterprise mortgages
• RegistryOfficial guidance

  PRH keeps the enterprise mortgage register. A mortgage stays valid until it is removed.

  Finnish Patent and Registration Office (PRH), enterprise mortgages

Usual security

General bond (tryggingarbréf) plus pledge of contract rights

Register

Not verified

Deadline

Not verified

• How the filed deals do itFiled deal

  Nscale Europe takes a first priority general bond (tryggingarbréf) over collateral in Iceland, with a negative pledge, plus a contractual rights pledge over each Icelandic data centre lease that includes the landlord's acknowledgement of step-in rights.

  Nscale Europe GPU credit agreement, Nscale S-1 Ex 10.14
• Statute and registryNot verified

  We could not retrieve the Icelandic statute from the parliament's site, so the legal basis, registration steps and any deadline are not stated here.

Usual security

Fixed and floating charges

Register

ACRA

Deadline

30 days (37 if created outside Singapore)

• RegistrationOfficial guidance

  New charges must be registered with ACRA within 30 days of creation, or 37 days where created outside Singapore. Charges that would need registration as a bill of sale, and floating charges, are on ACRA's list of registrable charges.

  ACRA, Registering a new charge (updated 12 June 2026)
• If it is missedOfficial guidance

  ACRA says an unregistered charge may become void against the liquidator or other secured creditors, and officers may be fined.

  ACRA, Registering a new charge (updated 12 June 2026)
• Statute textNot verified

  Singapore Statutes Online blocked our checks, so the section of the Companies Act is not cited directly.

Usual security

Fixed and floating charges

Register

Companies Registry

Deadline

One month

• Which chargesStatute

  Registrable charges include a charge that would need registration as a bill of sale if given by an individual, and a floating charge on the company's undertaking or property.

  Companies Ordinance (Cap. 622), Part 8
• RegistrationOfficial guidance

  Particulars and a certified copy of the charge instrument must be delivered within one month after creation, with a longer period for charges created outside Hong Kong over property outside Hong Kong.

  Companies Registry FAQ, registration of chargesCompanies Ordinance (Cap. 622), Part 8
• If it is missedStatute

  An unregistered charge is void against any liquidator and creditor so far as it gives security over the company's property, without affecting the obligation to repay.

  Companies Ordinance (Cap. 622), Part 8

Usual security

Security transfer of movables (jōto tanpo), perfected by registration

Register

Tokyo Legal Affairs Bureau, movables registry

Deadline

No fixed deadline; priority runs from registration

• The default ruleStatute

  A transfer of rights in movables cannot be asserted against third parties unless the movables are delivered.

  Civil Code, Article 178 (official translation)
• Registration insteadOfficial guidance

  Registering a transfer of movables is treated as delivery for that purpose. Only corporations can be the transferor. Priority between competing claims follows the time of registration or delivery.

  Ministry of Justice, 動産譲渡登記制度とはMinistry of Justice, 動産譲渡登記制度の概要
• Why it matters for GPUsOfficial guidance

  Where the borrower keeps using the servers, delivery can only be by agreement (sen'yū kaitei), which outsiders cannot see. The Ministry of Justice says registration exists to avoid the disputes that follow.

  Ministry of Justice, 動産譲渡登記 Q&A
• DurationOfficial guidance

  A registration lasts up to 10 years in principle, longer only for special reasons.

  Ministry of Justice, 動産譲渡登記 Q&A
• New law comingOfficial guidance

  A new act on security transfers and retention of title (Act No. 56 of 2025) was promulgated on 6 June 2025 and comes into force on a date set by cabinet order within two years and six months. It also revises the movables registration system.

  Ministry of Justice, 譲渡担保法について (updated 17 March 2026)

Usual security

Fixed and floating charges, usually in a debenture

Register

Companies Commission of Malaysia (SSM)

Deadline

30 days

• RegistrationStatute

  A company that creates a registrable charge must lodge a statement of particulars with the Registrar within 30 days of its creation. A person interested in the charge, such as the lender, may lodge it instead and recover the fees from the company.

  Companies Act 2016 (Act 777), s352 (SSM reprint, 1 August 2022)
• Which chargesStatute

  Registrable charges include a floating charge on the company's undertaking or property, a charge that would need registration as a bill of sale if given by an individual, charges on book debts and charges on deposit account balances.

  Companies Act 2016 (Act 777), s353
• If it is missedStatute

  The charge is void against the liquidator and any creditor so far as it gives security, and the money secured becomes immediately payable. The company and its officers also commit an offence.

  Companies Act 2016 (Act 777), s352(2), (3) and (10)
• Late filingOfficial guidance

  SSM says a statement lodged more than 30 days after creation cannot be registered unless a court order extending time is filed with it.

  SSM, Guidelines for registration of charges
• Read with careStatute

  Section 352(5) says failure to register a charge over property other than land does not affect the charge's validity. Read it with the voidness rule in section 352(2) and take local advice on how the two fit together.

  Companies Act 2016 (Act 777), s352(5)

On the regulatory trackerStrategic Trade Permit for US-origin AI chipsUS export controls on advanced AI chips

Usual security

PPSA security interest under a general security agreement

Register

Personal Property Securities Register (PPSR)

Deadline

20 business days after the security agreement, to avoid vesting on insolvency

• Enforceable against third partiesStatute

  A security interest is enforceable against third parties if it has attached and the lender has possession or control, or a written security agreement signed or adopted by the grantor describes the collateral. A statement covering all present and after-acquired property is enough.

  Personal Property Securities Act 2009, s20
• PerfectionStatute

  It is perfected if it is attached, enforceable against third parties and a registration is effective for the collateral, or the lender has possession or, for some collateral, control.

  Personal Property Securities Act 2009, s21
• PriorityStatute

  A perfected security interest beats an unperfected one. Between perfected interests, priority follows the priority time, usually the registration time.

  Personal Property Securities Act 2009, s55
• If it is unperfected on insolvencyStatute

  A security interest that is unperfected when the grantor goes into winding up or administration, or makes a deed of company arrangement, vests in the grantor immediately before that event. The lender becomes unsecured.

  Personal Property Securities Act 2009, s267
• The 20 business day ruleStatute

  An interest perfected only by registration also vests in the company if it was registered later than both 6 months before the insolvency event and 20 business days after the security agreement came into force, unless a court extends time. Register within 20 business days of signing.

  Corporations Act 2001, s588FL
• Leases of GPUsStatute

  A lease or bailment of goods for more than two years (or one that can run past two years) by a lessor regularly in the business of leasing is a PPS lease. The lessor needs to register to protect its title.

  Personal Property Securities Act 2009, s13

On the regulatory trackerSecurity of Critical Infrastructure Act 2018: data storage and processing

Usual security

Security interest in movables under Federal Law No. 4 of 2020, without possession

Register

Emirates Integrated Registries Company (EIRC), online movables register

Deadline

No fixed deadline; priority runs from registration (7 working days for acquisition finance priority)

• Non-possessory securityStatute

  A pledge over movable property can be created without handing possession to the lender, notwithstanding any other law. Registering the security in the Registry gives the lender all the rights it would have had in possession.

  Federal Law No. 4 of 2020, art. 5 (English text published by EIRC)
• How it is createdStatute

  The security contract must describe the collateral, which can be all of the grantor's property or a class of it, and the obligation secured. The executive regulations require the contract to be in writing. Equipment and fixtures are listed as collateral.

  Federal Law No. 4 of 2020, arts. 3 and 8Cabinet Resolution No. 29 of 2021 (executive regulations), art. 4
• Perfection and priorityStatute

  Security is effective against third parties by registering a notice, by possession or by control. A notice can be registered before the contract is signed, with the grantor's authorisation. Priority follows the date and time the security became effective against third parties, and a perfected interest ranks ahead of unsecured and preferential debts, including employee claims and unpaid taxes.

  Federal Law No. 4 of 2020, arts. 10 and 17
• Acquisition financeStatute

  Security that finances the purchase of equipment ranks ahead of earlier general security if its notice is registered within 7 working days after the grantor takes possession of the equipment.

  Federal Law No. 4 of 2020, art. 19
• Servers as fixturesStatute

  Security stays effective if the collateral becomes a fixture, including against mortgagees of the real property. The exception is where the asset was fixed before a mortgage was annotated on the property and that annotation came before the notice was registered.

  Federal Law No. 4 of 2020, art. 20
• Enforcement without courtStatute

  On default the lender may repossess and sell without going to court. It must give written notice at least 7 working days before the sale to the grantor and debtor, other registered secured parties, any third party holding the collateral and the owner or mortgagee of the property where the collateral is located: on a data centre deal, the landlord.

  Federal Law No. 4 of 2020, art. 27
• In bankruptcyStatute

  Security that is perfected when bankruptcy proceedings begin stays perfected and keeps its priority.

  Federal Law No. 4 of 2020, art. 39
• The registerOfficial guidance

  EIRC describes itself as the online register where lenders record their interest in movable assets used as collateral, and where lenders can search for registered interests. The regulations say the Registry does not check the content of a notice.

  Emirates Integrated Registries CompanyCabinet Resolution No. 29 of 2021, art. 3
• Text usedNot verified

  We read the English texts published by the registry; the law's English version is headed as a draft, and the Arabic text is the official one. The UAE legislation portal blocked our checks.

• Free zonesNot verified

  Whether the federal regime or a financial free zone's own security law (DIFC or ADGM) applies to the borrower and the site is not covered here.

On the regulatory trackerUAE moved to Country Group A:5Data Center Validated End User authorisation

Usual security

Commercial pledge under the 2018 Commercial Pledge Law

Register

Not verified

Deadline

Not verified

• The law in forceReference work

  The government's encyclopedia says the 2004 Commercial Pledge Law was repealed by a new law of the same name in 2018, which is in force, with implementing regulations of 47 articles issued in 2018. Articles 29, 30 and 31 were repealed and article 33 amended in 2019.

  Saudipedia (Ministry of Media), Commercial Mortgage Law in the Kingdom
• Statute and registryNot verified

  The Bureau of Experts and Ministry of Commerce sites refused connections from our checks, so the registration steps, any deadline, ranking and enforcement rules are not stated here.

On the regulatory trackerUS export controls on advanced AI chipsData Center Validated End User authorisation