When someone receives a signed document, the first thing they do is open it in Adobe and check that the signature shows as valid ✓. This guide explains what is behind that green mark — the commercial standard of the leading platforms worldwide — and how electronic signatures are regulated by the United States (ESIGN Act), Europe (eIDAS) and the laws of 17 countries.
The global commercial standard: the green mark that validates the document on any computer in the world.
The ESIGN Act defines no signature levels: no signature can be rejected for being electronic, and the evidence decides.
The European standard defines three levels: electronic, advanced and qualified signature.
No collective standard: each country has its own law, with its own levels and names.
In practice, your clients and counterparties do not consult their country's electronic signature law: they open the PDF in Adobe Acrobat or Reader and look at one thing only — that the signature shows as valid. That is the global commercial standard, and FirmaHoy meets the requirements of the Adobe AATL program just like DocuSign: a certificate from a program authority, a timestamp and the long-term format (PAdES-LTV).
The seal comes from a certificate issued by a trusted authority of the AATL program (Sectigo, DigiCert, GlobalSign…), which guarantees which platform sealed the document.
Cryptography detects any later alteration of the document: if a single letter is modified, the signature is no longer valid.
A trusted timestamp certifies the exact moment of signing, verifiable for years (PAdES-LTV).
The U.S. framework defines no signature levels — technological neutrality applies — and in a dispute the courts evaluate the evidence: who signed, how they were authenticated, what the audit trail records and that the document has not changed. That is why a signature with a cryptographic seal, timestamp and complete audit trail is best practice with U.S. counterparties.
It establishes that a contract or signature cannot be denied legal validity solely because it is in electronic form. It applies throughout the U.S. to interstate and international commerce.
The model adopted by 49 states and the District of Columbia (New York has its own law, ESRA, with the same effect). It complements the ESIGN Act at the state level.
The signer must perform a deliberate act to sign (click, stroke, code).
The parties agree to transact electronically (express or implied by conduct).
The signature must be attributable to the person: authentication, IP, email, audit log.
The signed document must be preserved intact and remain accessible to all parties.
The eIDAS Regulation is the European standard and the most influential international reference. It defines three levels: the higher the level, the more it demands from the signer and the stronger the legal backing. This is where FirmaHoy and DocuSign operate — and where it pays to understand what each label means.
The electronic data the signer uses to sign (Art. 3.10); the law cannot deny it legal effect or admissibility as evidence (Art. 25). FirmaHoy and DocuSign do more than the base: an Adobe AATL seal that prevents altering the document without invalidating the signature, a one-time code, an audit trail and a timestamp (PAdES-LTV).
FirmaHoy and DocuSign operate hereIt demands four requirements (Art. 26): uniquely linked to the signer, capable of identifying them, created with data the signer keeps under their exclusive control, and any later modification must be detectable. In practice it requires a certificate issued to the individual signer, with prior verification of their identity.
An advanced signature backed by a qualified certificate from an accredited provider and created with a qualified device. It is the only level with legal effect equivalent to a handwritten signature across the EU (Art. 25.2).
Does not exist in the U.S.Depending on the country it is called qualified, certified, digital or accredited — but it is always the same thing: a certificate each signer must process, receive and install before being able to use it. It is not created at the moment of signing, and understanding that process helps to know when it is truly needed.
The accredited provider verifies the applicant with their official identity document and a biometric proof (video confirmation or facial recognition, in person or remote depending on the country). Without this verification there is no certificate.
It is issued in that specific person's name. It cannot be shared or delegated: signing with someone else's certificate is equivalent to forging their signature.
The signer installs it on their computer or on a token, where the private key remains under their exclusive control, protected by a PIN or password.
It usually expires within 1 to 4 years; renewing it requires repeating the identity verification.
Nine practical criteria using the eIDAS levels as the frame of reference. FirmaHoy and DocuSign operate in the electronic signature column.
| Criterion | Electronic signature · FirmaHoy and DocuSign | Advanced signature | Qualified signature |
|---|---|---|---|
| Technology | Platform seal with an AATL certificate, one-time code (email/SMS/WhatsApp), audit trail and timestamp. | Certificate issued to the individual signer; keys under their exclusive control. | The holder's certified secure device: cryptographic token or HSM. |
| Who issues the certificate | The platform signs with its AATL certificate; the signer does not need to obtain one. | Commercial CA or trust service provider, in the signer's name. | Certification service provider accredited by the State. |
| Identity verification | Signer authentication with a one-time code and an audit record (who, when, from where). | Verification of the signer's identity before issuing their certificate. | Strict: official identity document + biometrics (video confirmation), in person or remote. |
| Delivery and installation | Nothing to install: you sign directly on the platform. | The signer processes and receives their certificate before being able to sign. | Personally assigned: the signer receives and installs it on their computer or token. |
| Value in court | Admissible under every law in this guide; its strength depends on the evidence: AATL integrity, authentication and audit trail. | Solid technical evidence; may require expert examination if challenged. | Legal equivalence to a handwritten signature; maximum evidentiary force. |
| Burden of proof | In general borne by whoever presents the document; in Colombia, agreed mechanisms are presumed reliable. | In general, borne by whoever submits the document. | It is reversed: whoever repudiates the signature must prove the fraud. |
| Timestamping | With FirmaHoy: timestamp and long-term PAdES-LTV format. | Depends on the provider; a timestamping authority (RFC 3161) is recommended. | Timestamping Authority (RFC 3161) and long-term PAdES-LTV format. |
| Ease for the signer | Immediate: one click or a code. | Medium: prior processing of the personal certificate. | Highly demanding: prior issuance procedure, installation and periodic renewal. |
| Does it exist in the U.S.? | Yes — valid under the ESIGN Act. | As a concept, no: the law defines no levels; the evidence counts all the same. | No. U.S. law does not define this level or an equivalent figure. |
Illustrative examples by field, according to the risk and formality of the act.
| Field | With FirmaHoy | Requires a state qualified / certified signature |
|---|---|---|
| Human Resources | Payroll receipts, attendance, vacations, employment contracts, addenda, non-disclosure agreements. | Powers of attorney, shareholder and board meeting minutes. |
| Banking and finance | App sign-ups, wallet terms, account openings, microloans, simple promissory notes. | Mortgages, collateral, trusts. |
| Commercial | Terms of service, quotes, acknowledgments, B2B purchase orders, standard contracts. | Real estate, share transfers, mergers (M&A). |
| Government | Petitions, informational forms, non-binding internal communications. | Public tenders, resolutions, public works. |
| Tax | Purchase receipt confirmations, internal system traceability. | Mass electronic invoicing with a local secure seal. |
| Healthcare | Appointments, care surveys, ordinary medical records, over-the-counter prescriptions. | Controlled substance prescriptions, clinical trials. |
| Business with the U.S. | Sign-ups, acceptance of terms, commercial contracts, NDAs, purchase orders. | Not applicable: this level does not exist in the U.S. |
There is no collective standard like the ESIGN Act or eIDAS: each country has its own law — some inspired by eIDAS, others by the UNCITRAL model, and several without an "advanced" category. The table summarizes the framework of 15 countries, with Spain and the U.S. as reference.
| Country | Main law | Recognized levels | Regulator | Effect of the highest level | ✓ Can be signed with FirmaHoy |
|---|---|---|---|---|---|
| Mexico | Commercial Code (arts. 89–114) and LFEA (2012) | Electronic Signature and "Reliable" AES (Commercial Code); the LFEA governs federal procedures only | SE (accredits CSPs) · SAT · SFP | AES: reinforced reliability; the SAT's e.firma (CFF 17-D) for tax matters. | Commercial and employment contracts, NDAs and purchase orders: valid with a method appropriate for the purpose (Commercial Code arts. 89 and 93). |
| Chile | Law 19,799 (2002) | Electronic signature and accredited AES | Accrediting Entity (Undersecretariat of Economy) | AES: full evidentiary value (art. 5); required for public instruments (art. 4). | Private, employment and commercial contracts (art. 3); evidentiary value under the general rules. |
| Colombia | Law 527 (1999) and Decree 2364 (2012, now Single Decree 1074/2015) | Electronic signature and Digital Signature (no "advanced" category exists) | ONAC (accredits) | Digital Signature: presumptions of authorship and integrity (Law 527, art. 28). | Same validity as handwritten (D. 2364, art. 5); mechanisms agreed between the parties are presumed reliable (art. 7). |
| El Salvador | Electronic Signature Law, D.L. 133 (2015, amended 2021) | Simple, Certified and Electronic Seal (no "advanced" exists) | Electronic Signature Unit (MINEC) | Certified: equated to handwritten, with presumptions (arts. 24-25). | The simple signature has the same legal validity as a handwritten one (art. 6); its evidentiary weight is assessed under sound judicial discretion — where the technical evidence counts. |
| Costa Rica | Law 8454 (2005) | Electronic document and Digital Signature (certified when issued by a registered certifier) | DCFD (MICITT); the BCCR operates the SINPE CAs | Certified Digital Signature: equivalence (art. 9) and presumption of authorship (art. 10). | Private documents: the non-certified signature is valid and assessed under sound judicial discretion. |
| Argentina | Law 25,506 (2001), Law 27,446 (2018) and Decree 182/2019 | Electronic Signature and Digital Signature | Secretariat of Innovation, Science and Technology (JGM) | Digital Signature: presumptions of authorship (art. 7) and integrity (art. 8). | Private and commercial contracts; if the electronic signature is repudiated, whoever invokes it proves its validity (art. 5). |
| Uruguay | Law 18,600 (2009) and Law 19,535 (2017) | Electronic signature and AES (including centrally-custodied AES) | UCE (AGESIC) | AES: identical validity to a handwritten signature in a public document (art. 6). | Private documents: effective if the parties admit it or the recipient accepts it (art. 5). |
| Peru | Law 27269 (2000), Legislative Decree 1412 (2018) and D.S. 029-2021-PCM | Simple, Advanced and Qualified (the qualified one is the IOFE digital signature) | INDECOPI (IOFE) | IOFE digital signature: same validity as handwritten. | Private contracts outside the IOFE, valid by agreement between the parties. |
| Guatemala | Decree 47-2008 and Regulation AG 135-2009 (amended 110-2020) | Electronic signature and AES | RPSC (MINECO) | AES: equated to handwritten; required for public instruments. | Commercial contracts and communications: valid with a reliable, appropriate method (art. 9). |
| Panama | Law 51 (2008), amended by Law 82 (2012) | Electronic and Qualified | National Electronic Signature Directorate (Public Registry) | Qualified: the signature requirements are presumed as a matter of law (art. 8). | Private and commercial contracts; without a qualified signature the reliability test applies and whoever invokes it bears the proof. |
| Paraguay | Law 6822/2021 and Decree 7576/2022 | Electronic and Qualified signature (there is no "advanced") | MIC (Digital Signature Directorate) | Qualified: equivalent to handwritten (art. 39.2) and reverses the burden of proof (art. 40.2). | Private and commercial contracts; the electronic signature cannot be denied effect (art. 39.1). |
| Ecuador | Law 67 (2002); the Digital Transformation Law (2023) does not alter the signature regime | A single type: electronic signature (art. 13) | ARCOTEL | Same validity as handwritten (art. 14); presumption when certified by an accredited entity (art. 53). | Private contracts and documents with full validity (art. 14). |
| Brazil | MP 2,200-2/2001 and Law 14,063/2020 | Simples, Avançada and Qualificada — only before public entities; between private parties there are no levels | ITI (ICP-Brasil) | Qualificada (ICP-Brasil): presumption of truthfulness (MP 2,200-2, art. 10 §1). | Documents between private parties: valid if the parties admit it or the recipient accepts it (art. 10 §2). |
| Dominican Rep. | Law 126-02 (2002) and Regulation D. 335-03 | Electronic signature and Digital Signature (with the attributes of art. 31) | INDOTEL | Digital signature with the attributes: same force as handwritten and presumptions (arts. 31-34). | Private contracts and documents: evidentiary force of privately signed acts (art. 9). |
| Honduras | Decree 149-2013 | Electronic Signature and AES | DIGEPIH (Property Institute) | AES: required for public instruments (art. 7). | Private and commercial contracts: same effects as written form (art. 6); without AES, evidentiary value under the general rules. |
| Bolivia | Law 164 (2011), D.S. 1793 and D.S. 3527/2018 | Digital document and certified Digital Signature | ATT · AGETIC (authorized certifier) | Certified Digital Signature: full legal validity (art. 78). | The most restrictive framework in the region: full validity requires an authorized certificate; private documents by agreement between the parties. |
| Spain | eIDAS Regulation 910/2014 (EU) and Law 6/2020 | Electronic, Advanced and Qualified (eIDAS) | Ministry for Digital Transformation | Qualified: equivalence to handwritten across the EU (eIDAS, art. 25.2). | Private, employment and commercial contracts; the electronic signature cannot be denied legal effect (art. 25.1). |
| United States | ESIGN Act (2000) and UETA (1999) | No levels: technological neutrality. The qualified signature does not exist. | No central authority; courts weigh the evidence | Same validity as handwritten with intent, consent and a record. | Private and commercial contracts with U.S. counterparties (ESIGN Act compliance). |