Qualified Electronic Signature for Non-EU Companies

Qualified electronic signatures for non-EU companies: when you need one

If your company is based outside the EU, you will usually meet the qualified electronic signature in an EU deal: a partner, a bank or an authority asks you to sign with a QES. eIDAS itself does not list which documents need one; that comes from the law that governs the document and from the people you deal with. These are the typical situations:

• The document needs the effect of a handwritten signature. Where the law that governs a contract or a declaration expects a handwritten signature, a QES is the electronic signature that eIDAS gives “the equivalent legal effect of a handwritten signature” (Article 25(2)).
• Your counterparty has to verify who you are. Banks, payment firms and other businesses covered by EU anti-money-laundering rules have to verify their customers’ identity, and those rules count “relevant trust services as set out in Regulation (EU) No 910/2014” among the sources they can rely on (Article 13(1)(a) of Directive (EU) 2015/849, as amended by Directive (EU) 2018/843). The Anti-Money Laundering Regulation, which applies from 10 July 2027, adds in recital 66 that where electronic identification is not available to a customer, for example because they live in a third country, “verification should take place through relevant qualified trust services”.
• You deal with public bodies online. For cross-border use of an online service offered by a public sector body, member states “shall not request … an electronic signature at a higher security level than the qualified electronic signature” (eIDAS Article 27(3)).
• You run a company in a member state. In Hungary, according to the Hungarian Chamber of Commerce and Industry, the representative of every business organisation has needed a qualified electronic signature for electronic administration and declarations since 1 November 2025. If you are the managing director of a Hungarian subsidiary, that includes you.

What eIDAS says about legal effect and recognition

The eIDAS Regulation (Regulation (EU) No 910/2014, as amended by Regulation (EU) 2024/1183) gives you three rules to rely on when you sign with EU partners:

1. Legal effect. “A qualified electronic signature shall have the equivalent legal effect of a handwritten signature.” (Article 25(2))
2. Recognition in every member state. “Qualified electronic signatures based on a qualified certificate issued in one Member State and qualified electronic seals based on a qualified certificate issued in one Member State shall be recognised, respectively, as qualified electronic signatures and qualified electronic seals in all other Member States.” (Article 24a(1)) A QES based on a certificate from a Hungarian provider is therefore a QES for your partner in Germany, the Netherlands or Italy.
3. No rejection for being electronic. Simpler electronic signatures can’t be rejected just for being electronic: an electronic signature “shall not be denied legal effect and admissibility as evidence in legal proceedings solely on the grounds that it is in an electronic form or that it does not meet the requirements for qualified electronic signatures” (Article 25(1)). The equivalence with a handwritten signature comes from Article 25(2), which applies to the QES.

If you want the background first, our article on what makes a signature qualified explains the requirements behind a QES.

One rule works the other way. eIDAS “does not affect Union or national law related to the conclusion and validity of contracts, other legal or procedural obligations relating to form, or sector-specific requirements relating to form” (Article 2(3)). If a member state requires a notarial deed or another formality for a transaction, eIDAS does not change that. Ask your EU partner, or their counsel, which form the document needs.

Can a certificate from a non-EU provider be qualified?

Only on the terms eIDAS sets. The regulation applies to “trust service providers established in the Union” (Article 2(1)). A qualified certificate for electronic signatures is one “issued by a qualified trust service provider” (Article 3(15)), and a qualified trust service provider is one that “is granted the qualified status by the supervisory body” (Article 3(20)). For providers outside the EU, Article 14(1) sets the condition:

“Trust services provided by trust service providers established in a third country or by an international organisation shall be recognised as legally equivalent to qualified trust services provided by qualified trust service providers established in the Union, where the trust services originating from the third country or from the international organisation are recognised by means of implementing acts or an agreement concluded between the Union and the third country or the international organisation pursuant to Article 218 TFEU.”

So before you rely on a signing certificate from a provider outside the EU, check whether such an implementing act or agreement covers that provider’s country. The simpler route is a provider that is already qualified in the EU.

Each member state publishes “trusted lists, including information related to the qualified trust service providers for which it is responsible, together with information related to the qualified trust services provided by them” (Article 22(1)), and you can look any provider up in the EU trusted lists. Netlock is on the Hungarian trusted list as a qualified trust service provider; its entry shows, among other services, qualified certificates for electronic signatures.

Which signature should a non-EU company use for EU deals?

Use a QES from an EU-qualified provider when a document needs the effect of a handwritten signature in the EU. The other options work only as far as your counterparty and the governing law accept them:

Does a QES also work in the US?

Yes, within limits: US federal law does not let a signature be denied legal effect just because it is electronic. The federal ESIGN Act defines an electronic signature as “an electronic sound, symbol, or process, attached to or logically associated with a contract or other record and executed or adopted by a person with the intent to sign the record” (15 U.S.C. § 7006(5)).

For transactions in or affecting interstate or foreign commerce, “a signature, contract, or other record relating to such transaction may not be denied legal effect, validity, or enforceability solely because it is in electronic form” (§ 7001(a)(1)).

A QES that you create with the intent to sign fits that definition. Two limits apply. ESIGN does not “require any person to agree to use or accept electronic records or electronic signatures”, apart from an exception for government agencies (§ 7001(b)(2)). And section 7001 does not apply to records governed by certain rules, for example those on “the creation and execution of wills, codicils, or testamentary trusts” (§ 7003(a)(1)). For a specific US document, check the law that governs it.

How a US person gets a Netlock QES remotely

Netlock identifies you remotely, so you can get a QES without travelling to the EU. It accepts the identity card and passport of every EU member state and, in the US, a passport or driver’s licence:

1. Sign up for free at app.netlock.com. The Netlock app is free to use.
2. Verify your identity with your US passport or driver’s licence, or an EU identity card or passport. In video identification you show the document to the camera of any device, then your face, and you don’t need a separate app. If you have a chip identity card, the Netlock mobile app is faster. The identification is automatic, and a member of our staff checks it when needed. Netlock holds the authorisation for remote video identification.
3. Get your qualified certificate. Netlock issues it free of charge. From registration to a working QES takes about 3 minutes, and the certificate is valid for 2 years.
4. Sign the contract. Upload your PDF, review it and sign it, on your phone or computer. You confirm each signature with two-step verification (MFA), and every signature gets a qualified time stamp. Your first 15 signatures are free; after that, each signature costs 1 credit (see pricing).
5. Invite the other side. Your EU counterparty, or a US colleague who has to co-sign, registers for free, gets a free qualified certificate, signs the document you invited them to and gets 15 free signatures of their own. Every signer automatically receives the signed copy by e-mail and can download it in the app.

The invite step matters in cross-border deals: signing never gets stuck on credits. You can cover the invitee’s signature from your own credits, and they can pay too, for example when your free credits have run out.

Practical tips for signing EU contracts from the US

1. Agree on the signature level in writing. Name the qualified electronic signature in the contract or in the message that sends it, so both sides expect the same thing.
2. Ask about formalities early. Find out which law governs the document and whether it needs a notary or another formality; eIDAS leaves those rules to EU and national law (Article 2(3)).
3. Check who may sign for the company. A QES identifies the person who signed; whether that person may bind your company is a separate question. Our article on why identity is not authority explains the difference.
4. Use an EU-qualified provider. Look the provider up in the EU trusted lists before your first signature.
5. Keep the signed file. Store the signed file itself; a printout or a scan loses the electronic signature.
6. Check what you receive. Before you rely on a signature from the other side, validate the electronic signature.
7. Consider a seal for documents your company issues. If a document comes from your organisation rather than from a person, read electronic signature or electronic seal to see which one fits.

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