Draft Implementing Regulation on Advanced Electronic Signatures and Seals: Ensuring Interoperability, SME Access, and International Alignment

October 2025

Our feedback supports the European Commission in refining the draft Implementing Regulation on advanced electronic signatures and seals, with a focus on ensuring interoperability, SME accessibility, and international alignment. Drawing on UNCITRAL and World Bank principles, we propose targeted amendments and advocate for the integration of trusted digital infrastructures’particularly the European Trade Indexes Registry (EUTIR)’to strengthen legal certainty, reduce administrative burdens, and position the EU as a global leader in secure, sustainable, and digitally enabled trade.