Date: 2025-09-30Category: Not ApplicableState: Union GovernmentCountry: Europe
Commission Implementing Regulation (EU) 2025/1945 of 29 September 2025 laying down rules for the application of Regulation (EU) No 910/2014 of the European Parliament and of the Council as regards the validation of qualified electronic signatures and of qualified electronic seals and the validation of advanced electronic signatures based on qualified certificates and of advanced electronic seals based on qualified certificates
Issued by European Commission
· Directorate-General for Communications Networks
**Executive Summary**
Commission Implementing Regulation (EU) 2025/1945, issued on September 29, 2025, establishes rules for validating qualified electronic signatures and seals under Regulation (EU) No 910/2014. It defines reference standards and specifications to ensure the integrity and authenticity of electronic signatures and seals, promoting the transition to electronic processes. The regulation enters into force twenty days after its publication in the Official Journal of the European Union.
**Key Points / Main Content**
* **Reference Standards and Specifications:**
* **For Qualified Electronic Signatures and Seals:**
* ETSI TS 119 172-4 V1.1.1 (2021-05) and ETSI TS 119 102-2 V1.4.1 (2023-06) apply with specific adaptations.
* Adaptations include adjustments to normative references and validation constraints.
* Signature validation applications must comply with ETSI TS 119 101.
* Defines processes for technical applicability checking.
* **For Advanced Electronic Signatures Based on Qualified Certificates and Seals:**
* ETSI TS 119 172-4 V1.1.1 (2021-05) and ETSI TS 119 102-2 V1.4.1 (2023-06) apply with specific adaptations.
* Adaptations include adjustments to normative references and validation constraints.
* Signature validation applications must comply with ETSI TS 119 101.
* Defines processes for technical applicability checking.
**Impact Analysis**
**Stakeholder: Relying Parties (Businesses, Organizations, Individuals)**
* **Impact:** Increased assurance of integrity and authenticity of signed or sealed data. Facilitates the transition from paper-based to electronic processes.
* **Action Required:** Adapt processes and systems to ensure compliance with the defined technical standards for validating electronic signatures and seals.
**Stakeholder: Validation Service Providers**
* **Impact:** Must adhere to the reference standards and specifications outlined in the regulation for validation processes.
* **Action Required:** Implement the technical standards and specifications detailed in the regulation and its annexes. Regularly update processes and systems to align with evolving standards and technologies.
**Stakeholder: European Commission**
* **Impact:** Responsible for regular assessment of new technologies and practices related to electronic signatures and seals.
* **Action Required:** Review and update the regulation, if necessary, to align with global developments, new technologies, standards, and best practices in the internal market.
Key Entities Referenced
Regulation (EU) No 910/2014: Regulation on electronic identification and trust services for electronic transactions in the internal market
Commission Implementing Regulation (EU) 2025/1945: Regulation laying down rules for the application of Regulation (EU) No 910/2014 as regards the validation of qualified electronic signatures and seals
European Parliament: One of the co-legislators in the EU.
Council: The other of the co-legislators in the EU
Official Journal EN
of the European Union L series
2025/1945 30.9.2025
COMMISSION IMPLEMENTING REGULATION(EU) 2025/1945
of 29 September 2025
laying down rules for the application of Regulation (EU) No 910/2014 of the European Parliament
and of the Council as regards the validation of qualified electronic signatures and of qualified
electronic seals and the validation of advanced electronic signatures based on qualified certificates
and of advanced electronic seals based on qualified certificates
THE EUROPEAN COMMISSION,
Having regard to the Treaty on the Functioning of the European Union,
Having regard to Regulation (EU) No 910/2014 of the European Parliament and of the Council of 23 July 2014 on
electronic identification and trust services for electronic transactions in the internal market and repealing
Directive 1999/93/EC(1), and in particular Article 32(3), Article 32a(3), Article 40 and Article 40a thereof,
Whereas:
(1) Qualified electronic signatures, qualified electronic seals, advanced electronic signatures based on qualified certificates
for electronic signatures and advanced electronic seals based on qualified certificates for electronic seals, provided
their validity can be confirmed, ensure to relying parties the integrity and authenticity of the signed or sealed data,
and enhance the certainty regarding the identity of the signatory or the seal creator. Those electronic signatures and
seals play a crucial role in the digital business environment by promoting the transition from traditional paper-based
processes to electronic equivalent ones.
(2) The presumption of compliance laid down in Article 32(1), Article 40, Article 32a(3) and Article 40a of Regulation
(EU) No 910/2014 should apply where the processes for the validation of qualified electronic signatures, of qualified
electronic seals, of advanced electronic signatures based on qualified certificates for electronic signatures and of
advanced electronic seals based on qualified certificates for electronic seals comply with the technical standards set
out in this Regulation. These standards should reflect established practices and be widely recognised within the
relevant sectors. They should be adapted to include additional controls ensuring the ability to verify the technical
validity of those signatures and seals, and, where applicable, their qualified status.
(3) The Commission regularly assesses new technologies, practices, standards or technical specifications. In accordance
with recital 75 of Regulation (EU) 2024/1183 of the European Parliament and of the Council(2), the Commission
should review and update this Regulation, if necessary, to keep it in line with global developments, new
technologies, standards or technical specifications and to follow the best practices on the internal market.
(4) Regulation (EU) 2016/679 of the European Parliament and of the Council(3) and, where relevant,
Directive 2002/58/EC of the European Parliament and of the Council(4) apply to all personal data processing
activities under this Regulation.
(1) OJ L 257, 28.8.2014, p. 73, ELI: http://data.europa.eu/eli/reg/2014/910/oj.
(2) Regulation (EU) 2024/1183 of the European Parliament and of the Council of 11 April 2024 amending Regulation (EU) No 910/2014
as regards establishing the European Digital Identity Framework (OJ L, 2024/1183, 30.4.2024, ELI: http://data.europa.eu/eli/reg/2024/
1183/oj).
(3) Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with
regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data
Protection Regulation) (OJ L 119, 4.5.2016, p. 1, ELI: http://data.europa.eu/eli/reg/2016/679/oj).
(4) Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing of personal data and
the protection of privacy in the electronic communications sector (Directive on privacy and electronic communications) (OJ L 201,
31.7.2002, p. 37, ELI: http://data.europa.eu/eli/dir/2002/58/oj).
ELI: http://data.europa.eu/eli/reg_impl/2025/1945/oj 1/6EN
OJ L, 30.9.2025
(5) The European Data Protection Supervisor was consulted in accordance with Article 42(1) of Regulation
(EU) 2018/1725 of the European Parliament and of the Council(5)and delivered its opinion on 6 June 2025.
(6) The measures provided for in this Regulation are in accordance with the opinion of the committee established by
Article 48 of Regulation (EU) No 910/2014,
HAS ADOPTED THIS REGULATION:
Article 1
Reference standards and specifications
1. The reference standards and specifications referred to in Article 32(3) and Article 40 of Regulation (EU)
No 910/2014 are set out in Annex I to this Regulation.
2. The reference standards and specifications referred to in Article 32a(3) and Article 40a of Regulation (EU)
No 910/2014 are set out in Annex II to this Regulation.
Article 2
Entry into force
This Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the
European Union.
This Regulation shall be binding in its entirety and directly applicable in all Member States.
Done at Brussels, 29 September 2025.
For the Commission
The President
Ursula VON DER LEYEN
(5) Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of natural persons
with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of
such data, and repealing Regulation (EC) No 45/2001 and Decision No 1247/2002/EC (OJ L 295, 21.11.2018, p. 39, ELI: http://data.
europa.eu/eli/reg/2018/1725/oj).
2/6 ELI: http://data.europa.eu/eli/reg_impl/2025/1945/ojEN
OJ L, 30.9.2025
ANNEX I
List of reference standards and specifications for the validation of qualified electronic signatures and
of qualified electronic seals
The standards ETSI TS 119 172-4 V1.1.1 (2021-05)(1)(‘ETSI TS 119 172-4’), and ETSI TS 119 102-2 V1.4.1 (2023-06)(2)
(‘ETSI TS 119 102-2’) apply with the following adaptations:
1. For ETSI TS 119 172-4
(1) 2.1 Normative references:
— [1] ETSI EN 319 102-1 V1.4.1 (2024-06) ‘Electronic Signatures and Trust Infrastructures (ESI);
Procedures for Creation and Validation of AdES Digital Signatures; Part 1: Creation and Validation’.
— All references to ‘ETSI TS 119 102-1 [1]’ shall be understood as references to ‘ETSI EN 319 102-1 [1]’.
— [2] ETSI TS 119 612 V2.3.1 (2024-11) ‘Electronic Signatures and Infrastructures (ESI); Trusted Lists’.
— [13] ETSI TS 119 101 V1.1.1 (2016-03) ‘Electronic Signatures and Infrastructures (ESI); Policy and
security requirements for applications for signature creation and signature validation’.
(2) 4.2 Validation constraints and validation procedures, requirement REQ-4.2-03, section ‘X.509 validation
constraints’, point c):
— (i) If an end-entity certificate represents a trust anchor, the RevocationCheckingConstraints shall not be
used.
— (ii) If an end-entity certificate does not represent a trust anchor, the RevocationCheckingConstraints shall
be set to ‘eitherCheck’ as defined in ETSI TS 119 172-1 [3], clause A.4.2.1, table A.2 rows (m)2.1.
— (iii) If an end-entity certificate represents a trust anchor, the RevocationFreshnessConstraints defined in
ETSI TS 119 172-1 [3], clause A.4.2.1, table A.2 rows (m)2.2 shall not be used.
— (iv) If an end-entity certificate does not represent a trust anchor, the RevocationFreshnessConstraints
defined in ETSI TS 119 172-1 [3], clause A.4.2.1, table A.2 rows (m)2.2 shall be used with a maximum
value of 24 hours for the signing certificate. No value shall be set for the RevocationFreshnessConstraints
for certificates other than the signing certificate, including certificates supporting time-stamps.
(3) 4.3 Requirements on signature validation and applicability rules checking practices
— REQ-4.3-02 Signature validation applications shall be compliant with ETSI TS 119 101 [13].
(1) ETSI TS 119 172-4 – Electronic Signatures and Infrastructures (ESI); Signature Policies; Part 4: Signature applicability rules (validation
policy) for European qualified electronic signatures/seals using trusted lists, V1.1.1 (2021-05).
(2) ETSI TS 119 102-2 – Electronic Signatures and Infrastructures (ESI); Procedures for Creation and Validation of AdES Digital Signatures;
Part 2: Signature Validation Report, V1.4.1 (2023-06).
ELI: http://data.europa.eu/eli/reg_impl/2025/1945/oj 3/6EN
OJ L, 30.9.2025
(4) 4.4 Technical applicability (rules) checking process
— REQ-4.4.2-03 If any of the checks specified in REQ-4.4.2-01 fails, then:
(a) the process stops;
(b) the signature shall be technically determined as indeterminate, i.e. as neither an EU qualified
electronic signature, nor as an EU qualified electronic seal; and
(c) the above result and the results of processes of all the intermediate processes shall be reflected in
the signature applicability rules checking report.
4/6 ELI: http://data.europa.eu/eli/reg_impl/2025/1945/ojEN
OJ L, 30.9.2025
ANNEX II
List of reference standards and specifications for the validation of advanced electronic signatures
based on qualified certificates and of advanced electronic seals based on qualified certificates
The standards ETSI TS 119 172-4 V1.1.1 (2021-05)(1)(‘ETSI TS 119 172-4’), and ETSI TS 119 102-2 V1.4.1 (2023-06)(2)
(‘ETSI TS 119 102-2’) apply with the following adaptations:
1. For ETSI TS 119 172-4
(1) 2.1 Normative references:
— [1] ETSI EN 319 102-1 V1.4.1 (2024-06) ‘Electronic Signatures and Trust Infrastructures (ESI);
Procedures for Creation and Validation of AdES Digital Signatures; Part 1: Creation and Validation’.
— All references to ‘ETSI TS 119 102-1 [1]’ shall be understood as references to ‘ETSI EN 319 102-1 [1]’.
— [2] ETSI TS 119 612 V2.3.1 (2024-11) ‘Electronic Signatures and Infrastructures (ESI); Trusted Lists’.
— [13] ETSI TS 119 101 V1.1.1 (2016-03) ‘Electronic Signatures and Infrastructures (ESI); Policy and
security requirements for applications for signature creation and signature validation’.
(2) 4.2 Validation constraints and validation procedures, requirement REQ-4.2-03, section ‘X.509 validation
constraints’, point (c):
— (i) If an end-entity certificate represents a trust anchor, the RevocationCheckingConstraints shall not be
used.
— (ii) If an end-entity certificate does not represent a trust anchor, the RevocationCheckingConstraints shall
be set to ‘eitherCheck’ as defined in ETSI TS 119 172-1 [3], clause A.4.2.1, table A.2 rows (m)2.1.
— (iii) If an end-entity certificate represents a trust anchor, the RevocationFreshnessConstraints defined in
ETSI TS 119 172-1 [3], clause A.4.2.1, table A.2 rows (m)2.2 shall not be used.
— (iv) If an end-entity certificate does not represent a trust anchor, the RevocationFreshnessConstraints
defined in ETSI TS 119 172-1 [3], clause A.4.2.1, table A.2 rows (m)2.2 shall be used with a maximum
value of 24 hours for the signing certificate. No value shall be set for the RevocationFreshnessConstraints
for certificates other than the signing certificate, including certificates supporting time-stamps.
(3) 4.3 Requirements on signature validation and applicability rules checking practices
— REQ-4.3-02 Signature validation applications shall be compliant with ETSI TS 119 101 [13].
(4) 4.4 Technical applicability (rules) checking process
— REQ-4.4.2-03 If any of the checks specified in REQ-4.4.2-01 fails, then:
(a) the process stops;
(b) the signature shall be technically determined as indeterminate, i.e. as neither an advanced electronic
signature based on EU qualified certificate, nor as an advanced electronic seal based on EU qualified
certificate; and
(1) ETSI TS 119 172-4 – Electronic Signatures and Infrastructures (ESI); Signature Policies; Part 4: Signature applicability rules (validation
policy) for European qualified electronic signatures/seals using trusted lists, V1.1.1 (2021-05).
(2) ETSI TS 119 102-2 – Electronic Signatures and Infrastructures (ESI); Procedures for Creation and Validation of AdES Digital Signatures;
Part 2: Signature Validation Report, V1.4.1 (2023-06).
ELI: http://data.europa.eu/eli/reg_impl/2025/1945/oj 5/6EN
OJ L, 30.9.2025
(c) the above result and the results of processes of all the intermediate processes shall be reflected in
the signature applicability rules checking report.
— REQ-4.4.2-04 void.
— REQ-4.4.2-05 void.
— REQ-4.4.2-06 At that point of the TARC process, if the following conditions are met:
(a) the signing certificate is determined, at the best signature time, as an EU qualified certificate for
electronic signatures (respectively for electronic seals), as specified in REQ-4.4.2-02 a); and
(b) the result of the process performed as specified in clause 4.2 of the present document is TOTAL-
PASSED,
then the digital signature shall be determined as technically suitable to implement an EU advanced
electronic signature based on a qualified certificate (respectively an EU advanced electronic seal based on
a qualified certificate), otherwise the signature shall not be determined technically either as an EU
advanced electronic signature based on a qualified certificate, or as an EU advanced electronic seal based
on a qualified certificate.
6/6 ELI: http://data.europa.eu/eli/reg_impl/2025/1945/oj