Global guide to electronic signature law: Which countries accept e-signature legally? (Infographic)
- Electronic signatures are legally recognized in 80+ countries, and in most everyday cases they’re considered legally binding when consent, intent, and reliable authentication are in place.
- In the U.S., the Electronic Signatures in Global and National Commerce Act (the ESIGN Act) and state-level Uniform Electronic Transactions Act (UETA) make clear a contract or other record can’t be denied legal effect simply for being digital—i.e., denied legal effect validity or validity or enforceability solely because it’s electronic.
- The EU uses a tiered model under eIDAS (updated by federal law-like EU regulation), where qualified electronic signatures often have the same legal status as traditional handwritten signatures, while advanced electronic signatures fit many higher-trust business needs.
- Across jurisdictions, enforceability typically hinges on: intent to sign, clear consent to proceed electronically, trustworthy authentication methods, integrity protection, and strong audit trails plus record retention for electronic records.
- Some certain documents may still be excluded or require stricter formalities (often including “wet ink”): examples can include wills and some family law documents (like adoption papers) or particular real estate transactions, depending on local state law and international laws.
If you manage contracts, HR paperwork, sales approvals, procurement, or customer onboarding—this guide is for you. It’s also useful for founders and ops teams trying to close deals faster, legal teams building a defensible legal framework, and anyone who needs to sign documents electronically across borders.
Learn how electronic signatures work globally, what “legally binding” really means, the big differences between the U.S. and EU approaches, when exceptions apply (including family law matters), and what to look for in electronic signature solutions like SignNow.
From squiggles to statutes: How e-signing became normal
Before e-sign laws, many organizations defaulted to “paper is safest.” But global commerce moved online—so lawmakers clarified that a signature isn’t about ink; it’s about agreement.
In the U.S., the landmark was the Electronic Signatures in Global and National Commerce Act—often shortened to the national commerce act or National Commerce Act in casual conversation, but formally known as the Electronic Signatures in Global and National Commerce law (ESIGN Act).
Its core principle: a signature, contract, or other record relating to such transaction in foreign commerce or global and national commerce cannot be denied legal effect, legal status, legal validity, or effect validity or enforceability enforceability solely because it is electronic or because it was signed electronically.
Separately, at the state level, the Uniform Electronic Transactions Act (UETA) provided a model for uniform electronic transactions—basically standard rules for when people agree electronically and keep electronic records instead of paper. It emphasizes party consent: the law generally applies when the parties have agreed to proceed electronically.
Internationally, many regimes share similar goals: keep trade moving, support modern contracting, and make sure electronic processes remain trustworthy.
What “legally binding” actually means for eSignatures
Let’s make this concrete. A legally binding electronic signature means that, if there’s a dispute, the signature can be treated as evidence that the signer agreed—similar to a handwritten signature on paper—so the agreement can be enforced.
Most systems focus on these elements:
Consent and capability
- The parties must agree to do business digitally (often explicit, sometimes implied by context).
- Many workflows include a standard consent clause so there’s no confusion about receiving electronic documents or notices.
Intent to sign
Legal definitions commonly require the signer to execute or adopt an electronic signature with the intent to sign. That’s why “typed name + click to sign” can be valid when the signing experience clearly shows what’s happening.
Authentication and attribution
The key question in disputes is: “Was it really the signer?” That’s where authentication methods matter—email verification, SMS codes, knowledge-based checks, ID verification, or certificate-based signing, depending on risk and law.
Integrity and tamper-evidence
If a signed electronic form can be altered after signing, enforceability gets shaky. Strong platforms help preserve integrity so the final electronic records are accurately reproduced later.
Evidence: audit trails + retention
Courts and regulators love documentation. Good electronic signing includes audit trails (timestamps, IP addresses, signer actions) and clear record retention procedures.
Bottom line: electronic signatures are legally effective when you can show who signed, what they signed, and that they meant to sign it—especially in transactions involving two or more persons.
Electronic signatures in global business: Legal models
When people talk about electronic signatures in global business, they’re usually dealing with one of these approaches:
1) Tech-neutral (broad acceptance)
This model says: “We don’t care what tech you use, as long as it’s reliable and everyone consents.” This tends to be the most flexible for businesses operating at speed.
Common pattern:
- If parties agree to proceed electronically and the method is generally accepted as reliable, it’s usually fine.
- The fight is rarely “Is an e signature valid?” and more “Can you prove the signer’s identity and intent?”
2) Tiered (risk-based levels)
This model recognizes multiple signature levels. The EU is the famous example:
- Simple electronic signatures (often used for low-risk)
- Advanced electronic signatures (stronger linkage to the signer)
- Qualified electronic signatures (often the highest level, commonly involving qualified certificates and a regulated provider—i.e., a trust service provider)
Tiered models are popular because they align legal weight with risk: not every NDA needs the same rigor as a notarized filing.
3) PKI-prescriptive (certificate-driven)
Some jurisdictions strongly prefer or require PKI-based signing for full legal presumption. This is where digital certificates come in—cryptographic credentials that tie a signature to a verified identity.
This approach is powerful for high-trust scenarios, but can add friction if you’re trying to onboard users quickly.
Country snapshots: How eSignature acceptance looks in practice
This isn’t legal advice—just the practical “shape” of the landscape so you can plan cross-border workflows.
United States
In the U.S., both the ESIGN Act and UETA work together:
- ESIGN is a federal law covering transactions in or affecting interstate or foreign commerce—i.e., modern national commerce.
- UETA (state law model) supports uniform electronic transactions and requires that parties have agreed to conduct business digitally.
Under these laws, a signature/record generally can’t be denied legal effect validity or denied legal effect validity or enforceability solely because it’s electronic. This is the heart of U.S. e signature law: the format doesn’t kill enforceability; bad process does.
Also helpful: UETA’s definition of an electronic signature includes an electronic sound, symbol, or process attached to or logically associated with a record and executed or adopted with intent. (That “electronic sound” language surprises people, but it’s real.)
European Union
The EU’s eIDAS framework is tiered and built around trust services:
- Qualified electronic signatures can carry the same legal validity / same legal status as traditional handwritten signatures in many contexts.
- For higher-risk workflows, the involvement of a regulated trust service provider and qualified certificates can matter a lot.
The EU’s digital identity direction is accelerating, with the EU Digital Identity Wallet framework requiring member states to make wallets available by the end of 2026.
Why this matters for cross-border teams
If your customers or counterparties span regions, the practical move is to design a signing process that can satisfy the strictest environment you expect to face—without forcing maximum friction on every low-risk form.
ESIGN vs. eIDAS: The difference in one minute
Here’s the simplest way to think about it:
U.S. approach: “Don’t deny it because it’s electronic.”
The ESIGN principle is technology-neutral and focused on preventing the “paper-only” trap. If you can prove the deal and the signature, you’re usually in good shape for everyday commercial affairs.
EU approach: “Use tiers of trust.”
The EU focuses on signature levels with stronger presumptions as you move up. If you need the closest equivalent to a wet signature, that’s where Qualified Electronic Signatures come in.
In plain terms:
- U.S.: easier baseline adoption
- EU: clearer pathways for high-trust signing
When eSignatures may not apply
Even where electronic signatures legal frameworks exist, laws often carve out categories. You’ll commonly see restrictions (or extra formalities) around certain documents like:
- Wills and testamentary documents
- Some family law documents and family law matters (including adoption papers in some places)
- Some real estate transactions (especially those requiring notarization or special recording)
- Court orders and specific notices
The practical rule: if the law explicitly says “law requires” a particular formality, don’t try to brute-force it with a basic click-sign. Where parties historically would agree manually and notarize, you may need higher assurance (or a different workflow entirely).
How to make electronic signatures defensible (and fast)
If you want e-signing that’s not just convenient but strongly enforceable, focus on process:
1) Capture consent clearly
Use a visible consent step and keep the wording simple. Include a standard consent clause where required, especially when delivering disclosures as electronic documents.
2) Prove identity proportionate to risk
Match your authentication methods to the stakes:
- Low risk: email + access control
- Medium risk: SMS/OTP, stronger account authentication
- High risk: ID verification, or certificate-based methods using digital certificates
3) Protect integrity
Use a platform that seals the document after signing and preserves an unbroken chain of evidence. If challenged, you want to show the record was not altered.
4) Keep excellent records
Good record retention is non-negotiable. Make sure signed files can be stored, exported, and reproduced—accurately reproduced—for the required period, with the audit evidence attached.
5) Don’t over-complicate low-risk workflows
Many agreements don’t need the maximum tier. The goal is “reliable enough” + “easy enough” so people actually complete the process.
Myth-busting: quick reality checks
Myth: “E-signatures aren’t legally binding.”
Reality: In many countries, signatures are legally binding when consent + intent + reliability are present, and the agreement isn’t in an excluded category.
Myth: “If it’s electronic, it must be a digital signature.”
Reality: digital signatures are a subset of electronic signatures, typically using cryptography and certificates. Many valid e-signs aren’t PKI-based.
Myth: “The EU requires QES for everything.”
Reality: Many contracts can use lower levels; QES is typically reserved for higher-trust situations or where required by rules.
Where SignNow fits: Practical e-signing for real teams
If your goal is to sign faster without losing confidence:
- Use templates to standardize the electronic process
- Collect signatures in the right order and track completion
- Keep built-in audit trails
- Centralize storage for electronic records and electronic documents
- Reduce error rates in every electronic form you send
The result: smoother contracting, fewer delays, and a signing process that’s easier to defend if questioned.

Final thoughts
The world has moved from traditional handwritten signatures to digital workflows because modern commerce demands it. The good news is that in many places, contracts won’t be denied legal effect just because they’re digital—what matters is whether you followed the legal requirements: consent, identity, confidence, integrity, and evidence.
If you’re ready to move your agreements forward—securely, quickly, and with the auditability you need—start a free trial with SignNow and put a repeatable, compliant electronic signing flow in place today.
Glossary
- Electronic signature: A legally recognized method of indicating agreement in digital form—often defined as an electronic sound, symbol, or process tied to a record and executed with intent to sign.
- ESIGN Act: U.S. federal law that says signatures and electronic records in transactions affecting interstate or foreign commerce can’t be denied enforceability just because they’re electronic.
- UETA: A state-law model that supports uniform electronic transactions, giving e-signs and e-records legal effect when parties agree to transact electronically.
- Advanced / Qualified electronic signatures (AES / QES): Higher-assurance signature categories in tiered regimes; QES often has a legal presumption similar to a handwritten signature and typically involves regulated trust services.
- Audit trail: A tamper-evident log of who signed, when, how, and what actions occurred—critical evidence supporting the signature’s legal effect.
Sources
[1] U.S. ESIGN Act — govinfo.gov/content/pkg/PLAW-106publ229
[2] UNCITRAL Model Law — uncitral.un.org/en/texts/ecommerce/modellaw/electronic_signatures
[3] EU eIDAS Regulation — ec.europa.eu/digital-building-blocks/esignature
[4] Global eSignature Laws — onespan.com/resources/esignature-legality
[5] eSignature Market Data — llcbuddy.com/data/e-signature-statistics
[6] Country-Specific Regulations — pandadoc.com/electronic-signature-law
FAQ
- Are electronic signatures legal worldwide?
Many countries recognize them, but requirements vary by jurisdiction and by document type. For cross-border deals, plan for the strictest regime you’ll encounter. - Are electronic signatures legally binding the same as handwritten signatures?
Often yes for everyday contracts—especially where the law grants same legal validity or prevents contracts from being denied legal effect solely for being electronic. Some jurisdictions reserve “handwritten-equivalent” status for higher-trust signatures (like qualified electronic signatures).
- What makes an electronic signature enforceable?
Clear consent to proceed electronically, strong proof of the signer’s identity, demonstrated intent to sign, document integrity, and usable evidence like audit trails plus record retention. - Do any documents require handwritten signatures?
Yes—some certain documents can be excluded or require special formalities (common examples include some wills, some family law documents, and certain real estate transactions, depending on local state law). - What’s the difference between electronic signatures and digital signatures?
Electronic signatures are the broad category. Digital signatures typically use cryptography and digital certificates to provide stronger identity assurance and integrity protection. - How do I choose the right signature type for my business?
Match risk to assurance: low-risk forms can use simpler methods; regulated or high-stakes agreements may justify stronger authentication or certificate-based signing—especially when dealing with international counterparties and international laws.
- From squiggles to statutes: How e-signing became normal
- What “legally binding” actually means for eSignatures
- Electronic signatures in global business: Legal models
- 1) Tech-neutral (broad acceptance)
- 2) Tiered (risk-based levels)
- 3) PKI-prescriptive (certificate-driven)
- Country snapshots: How eSignature acceptance looks in practice
- ESIGN vs. eIDAS: The difference in one minute
- When eSignatures may not apply
- How to make electronic signatures defensible (and fast)
- Myth-busting: quick reality checks
- Where SignNow fits: Practical e-signing for real teams
- Final thoughts
- Glossary
- Sources
- FAQ