A practical guide for those working with foreign partners
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You signed an agreement with a foreign partner via eParaksts – is it recognized in their country?
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Did you know that different countries have different electronic signature standards—and that an “electronic signature” in Russia and Latvia is not the same legal term?
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What should I do if my partner cannot or does not want to sign documents electronically?
A Latvian company sent a contract with eParaksts to a partner in Kazakhstan. The partner responded, “We don’t recognize Latvian electronic signatures. We need the original with a seal.” Negotiations dragged on for two weeks.
Electronic Signature Standards: Three Levels
The European Union has the eIDAS Regulation, which establishes three levels of electronic signature: a simple electronic signature (a scan of the signature, clicking the “tick”), an enhanced electronic signature (with a cryptographic key but without a qualified certificate), and a qualified electronic signature (with a qualified certificate from an accredited provider).
Only qualified electronic signatures (eIDAS) are automatically recognized in all EU countries and have the same legal force as a handwritten signature. These include eParaksts in Latvia, ID-kaart in Estonia, itsme in Belgium, and so on.
Recognition in EU countries
A qualified electronic signature issued by an accredited provider in any EU country is automatically recognized in all EU countries—this is a requirement of the eIDAS Regulation. Latvia’s eParaksts are recognized in Germany, France, Poland, Estonia, and any other EU country.
For EU partners: Offer to sign using a system that supports eIDAS-compatible signatures—for example, DocuSign (with qualified signature settings), Adobe Sign—or exchange documents signed with each of your national qualified signatures.
CIS countries and Russia
CIS countries have their own electronic signature standards that are not compatible with eIDAS. The Russian Enhanced Qualified Electronic Signature (EQES) is not automatically recognized in Latvia. The Latvian eParaksts is not automatically recognized in Russia or Kazakhstan.
A practical solution for transactions with CIS partners: if it’s not possible to establish a mutually recognized system, exchange signed scans via email. This is more secure than electronic signatures, which the other party cannot verify.
USA and Great Britain
In the US, the ESIGN and UETA laws broadly recognize electronic signatures, including simple electronic signatures (such as clicking “I agree” or inserting a signature into a PDF). This is less stringent than eIDAS.
American partners generally accept documents signed through DocuSign or similar services. They also accept qualified European signatures, but they may be unfamiliar with them.
Universal solutions
For international transactions involving parties from different jurisdictions, the most practical options are:
Option one: DocuSign, Adobe Sign, or similar solutions that support qualified signatures via eIDAS. A partner from any country can sign using their own method, and the system will record the signature.
Option two: exchanging signed originals by mail. Old-fashioned, but versatile. For long-term transactions, it’s more reliable than arguing over the recognition of electronic signatures.
Option three: notarization with an apostille. For particularly important documents, a notary certifies the signatures, then affixes an apostille. Accepted in all Hague Convention countries.
Checklist before signing with a foreign partner
Determine the partner country
Check the requirements for document formats in this country
For the EU - eIDAS compliant qualified signature
For the CIS countries, exchange of scans or originals
For the US/UK - DocuSign or equivalent
For particularly important documents - notary + apostille
An electronic signature works within the jurisdiction. Outside of it, you need to know the rules.
This article is for informational purposes only and does not constitute legal advice.