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The impact of the Electronic Signature Directive on the effectiveness of the trade in the frame of internal market of EU

    

           In civil and common law countries alike, the enforceability of many types of contracts is subject to certain formalities. The most common formality is the requirement of writing and signature. Several reasons for formal requirements have been advanced, including preserving evidence, putting parties on notice, signaling the transition from negotiation to contract, and providing information. Conversely, several disadvantages to contract formalities also have been identified.

         These disadvantages include: inhibiting freedom of contract, slowing the “free flow of commerce,” and allowing a party to defeat justified expectations. Of these three, the impediment to the “free flow of commerce” presents the greatest potential obstacle to e–commerce. Unless electronic documents are treated as “writings” which can be “signed,” paper records will have to supplement many electronic transactions, resulting in e–commerce that is “more expensive, less competitive, and less efficient.”

          On June 18, 1999, the European Council reached a common position on the Signature Directive. The primary aim of the Signature Directive is to create a “harmonized and appropriate legal framework for the use of electronic signatures within the Community and to establish a set of criteria which form the basis for legal recognition of electronic signatures”. The Signature Directive defines an “electronic signature” as “data in electronic form which are attached to or logically associated with other electronic data and which serve as a method of authentication.” The principal effect of the E-Signatures Directive is to make electronic signatures legally valid in relation to data in electronic form in the same manner as a handwritten signature is valid in relation to paper-based data. Member states are obliged to ensure that an electronic signature is not denied legal effectiveness and admissibility as evidence in legal proceedings solely on the grounds that it is in electronic form.

         The E–Signature Directive recognizes the validity of two types of signatures: an electronic signature and an advanced electronic signature. The former should not be denied legal effectiveness and admissibility as evidence in legal proceedings solely on the grounds that it is in electronic form.

         The Electronic Communications Act 2000, s 7 is an attempt to put the position beyond doubt. It states that electronic signatures are admissible in legal proceedings as evidence of the authenticity or integrity of a communication. Section 7 does not prescribe any particular method of signature so various ways of using electronic signatures are possible and each signature will be admissible in legal proceedings. Interestingly, although the Act deals with the admissibility of an electronic signature in court, it does not actually address the legal status of electronic signatures [2,150p.]. The advanced electronic signature satisfies the legal requirements of a signature in relation to data in electronic form in the same manner as a hand–written signature satisfies those requirements in relation to paper–based data and is admissible as evidence in legal proceedings. The advanced signature qualifies only when it is based on a qualified certificate, which is defined in Annex I and Annex II of the Directive. The qualified certificate must also be based on a secure signature creation device, which should meet the requirements of Annex III. In order for an advanced electronic signature to meet the legal requirements, it has to satisfy the criteria of Annexes I, II and III.

          Article 4(2) of the Directive[1] urges the Member States to ensure that electronic signature products complying with the Directive are permitted to circulate freely in the internal market. Recital 5 specifies, ‘the interoperability of electronic signature products must be met in order to ensure free movement within the internal market and to build trust in electronic signatures, without prejudice to the regulation regarding dual – use goods.

          Article 3(5) provides that the Commission may, in accordance with the procedure laid down in Article 9, establish and publish reference numbers of generally recognized standards for electronic signature products in the Official Journal of the European Communities. Member States shall presume that there is compliance with the requirements laid down in Annex ii, point (f), and Annex iii when an electronic signature product meets those standards.

        According to the Signature Directive, an “advanced electronic signature” is an electronic signature if [4, 320]:

·     it is uniquely linked to the signatory;

·     it is capable of identifying the signatory;

·     it is created using means that the signatory can maintain under his sole control; and

·     it is linked to the data to which it relates in such a manner that any subsequent alteration of the data is detectable.

         The Signature Directive takes a two–tiered approach in defining the legal effects of an electronic signature. The first tier requires Member States to “ensure that an electronic signature is not denied legal effectiveness and admissibility as evidence in legal proceedings” solely because it is a) not in electronic form, b) not based on a qualified certificate or not based on a qualified certificate issued by an accredited certification–service–provider, or c) not created by a secure signature–creation device. A “certificate” is an “electronic attestation which links signature–verification data to a person and confirms the identity of that person.” A “qualified certificate” is a certificate that meets specific security standards and is issued by a qualified “certification–service–provider,” more commonly known as a CA. The Signature Directive lays down requirements for qualified certificates and CAS in Annexes I and II, respectively. Similarly, requirements for a “secure–signature–creation device” are laid down in Annex III. The first level of legislation accepts most electronic signatures on a technologically–neutral basis.

         The second tier of legal validation entitles qualified technologies to legal equivalency with handwritten signatures. The Signature Directive requires Member States to ensure that advanced electronic signatures which are based on a qualified certificate and which are created by a secure–signature–creation device

·     it satisfies the legal requirements of a signature in relation to data in electronic form in the same manner as a handwritten signature satisfies those requirements in relation to paper–based data, and

·     admissible as evidence in legal proceedings.

         The EU Electronic Signatures Directive (Directive 1999/93/EC) marks the EU's approach to the regulation of electronic signatures. The stated aim of this directive is to "create a harmonised and appropriate legal framework for the use and legal recognition of electronic signatures within the EU."  The Directive requires that member states enact legislation that affords legal recognition to "electronic signatures that are based on a 'qualified certificate'" so long as they were "created by a 'secure–signature–creation device ...'"  While a contract that fulfills Article 5 is per se valid, other contracts are not necessarily invalid.

      The EU Directive does not require a specific type of technology, but allows for technological adaptation that fulfills the secure–signature–creation requirement. Certification Service Providers (CSPs) will provide the service of fulfilling this requirement. In turn, "CSPs will be liable to anyone who relies upon an issued certificate."

         The Signature Directive’s two–tiered structure strives to reach a middle ground between technology–specific and enabling approaches. On the one hand, the Signature Directive enables the use of all electronic signatures by mandating their “legal effectiveness and admissibility as evidence in legal proceedings.”On the other hand, it promotes digital signature technology by creating a presumption that “advanced electronic signatures which are based on a qualified certificate satisfy the legal requirements of a signature in the same manner as a handwritten signature” [5]. This presumption is limited functionally to digital signatures because qualified certificates are unique to PKI technology.

Under the Signature Directive, authentication methods that qualify as “advanced electronic signatures,” created by a “secure–signature–creation device” but not based on a qualified certificate, appear to fall short of presumptive equality with handwritten signatures. It follows that signatures created through signature dynamics would not enjoy the same presumptive validity as digital signatures because they provide direct proof of signer identity rather than relying on “a complex system of trusted third parties Thus, under the current Signature Directive, a business using an otherwise “secure” signature method that is not a digital signature subject to a qualified certificate risks creating an unenforceable or voidable contract. This is not “technological neutrality” but rather technological “favoritism.”

         As between the technology–specific and technology–neutral approaches, it is the latter that comports with the principles suggested by this maxim. Businesses that engage in sound commercial business practices will, as they currently do, choose methods for signing their computer documents that meet their commercial needs. Businesses should use digital signatures because they solve practical problems created by open network transactions, not because the law dictates their use. “The technology implementation itself provides the necessary security and certainty necessary for electronic commerce without the need for legislative intervention.” Thus, laws favoring digital signatures are not needed to create a “security infrastructure.”

        In its present form, the Signature Directive appears to favor digital signatures to the potential detriment of other current and future technologies[3]. Encouraging the use of digital signatures is superfluous to achieving the Signature Directive’s goals of Market harmonization.  Simply validating currently held broad interpretations of what is a “writing” is sufficient to remove fears that electronic contracts will be held invalid. For example, Ireland is considering this better reasoned approach and recently unveiled an outline for electronic signature legislation. This outline borrows the Signature Directive’s first tier of validation, but notably leaves out the second tier.

          The future treatment of electronic signatures regulation is likely to continue on the same track as current trends. That is, technology has taken the lead over legislation further than legislation has restrained or guided technology. The EU Electronic Signature Directive is an example of this relationship. The Directive utilizes the technology available, while remaining flexible to accept future technologies, to ensure that electronic contracts can be given the same evidentiary standing as traditional contracts. Technologies such as secure–signature–creation and the forethought to allow commercial CSPs to turn electronic contract verification into an industry are signs of future legislation. The type of adaptation that the EU Directive explicitly allow for will provide room for future, more secure, and reliable technologies. While the EU Directive allows for non–EU CSPs to offer their services within the EU, there are no international agreements for global acceptance of such electronic contract verification. A multilateral convention or international consortium outlining standards for the global recognition of CSPs would support e–commerce growth on a larger international scale.

 

 

List of Literature:

1.     Directive 1999/93/EC of the European Parliament and of the Council of 13 December 1999 on a Community framework for electronic signatures, http://eur–lex.europa.eu

2.    Mike Butler E– Convergence: A Guide to the Law of Digital Media,– ‘Bloomsburry Professional LTD’, Great Britain, 2001

3.     Stephen Errol Blythe, E–Commerce Law around the world, – ‘ Xibris Corporation’ kindle edition, 2011

4.     Quinten Kroes. E– Business Law of the European Union, – ‘Wolters Kluwer’, Great Britain, 2010

5.     Faye Fangfei Wang. Law of Electronic Commercial Transactions. Contemporary issues in the EU, US and China, – ‘Taylor & Francis’, kindle edition, 2010