Legality of eSignatures in Ukraine

Background

Electronic signatures have become a cornerstone of the modern document authentication landscape in Ukraine, offering legal validity, security, and efficiency in both business operations and government services in an increasingly digital world. Internationally, they streamline workflows by reducing delays, eliminating the need for physical paperwork through environmentally conscious methods, and reducing expenses for courier services, scanning, and printing.

Choosing of an eSignatures service that complies with Ukraine’s legal stipulations, especially Law of Ukraine “On Electronic Trust Services” No. 2155-VIII as of 5 October 2017 (Law on Electronic Trust Services) is vital for successful adoption, compliance, and effectiveness. The law warrants legal validity for electronically signed documents with the same status as handwritten signatures¹. Even though electronic signatures are widely accepted in Ukraine, some documents require physical signatures, and seeking legal counsel is advisable to navigate local regulatory nuances.

The importance of security surrounding electronic signature platforms cannot be understated. Services must integrate robust protection features such as data encryption, verification of signer identities, and provision of audit trails to deter unauthorized access and ensure document authenticity. For instance, BoldSign offers these imperative security features, which comply with legal and security protocols.

For enterprises in Ukraine, it is essential to emphasize legal conformity, elevate security measures, and choose user-friendly platforms for integrating electronic signatures into their business frameworks. This approach not only boosts productivity, but also ensures the protection of their business exchanges.

Overview of the eSignature regulations in Ukraine

Electronic transactions and eSignatures in Ukraine are regulated by the following laws:

Law of Ukraine “On Electronic Trust Services” No. 2155-VIII as of 5 October 2017 (Law on Electronic Trust Services).
Code of Ukraine No. 435-IV of January 16, 2003; “Civil Code of Ukraine.”²

The law on Electronic Trust Services provides that an electronic signature in Ukraine may not be declared invalid and deprived of the possibility of being considered as evidence in legal proceedings solely on the grounds that it is in electronic form or does not meet the requirements for a qualified electronic signature³.

The cabinet of ministers in Ukraine set the procedure for using electronic trust services in state authorities, local self-government bodies, enterprises, institutions, and organizations of state ownership⁴.

The law on Electronic Trust Services categorizes eSignatures into:

Simple electronic signature (SES)
Advanced electronic signature (AES)
Qualified electronic signature (QES)

A simple electronic signature (SES) is any data in electronic form that is attached or logically associated with other data in electronic form, and which is used by the signatory to sign a document⁵. SES provides a limited degree of trust; however, technical control measures should be established to ensure no misuse of identification data and identity refutation⁶.

An advanced electronic signature (AES) is a type of electronic signature that must⁷:

Be created by means of cryptographic conversion of electronic data to which this signature is linked.
Be created with the use of an advanced electronic signature device and a personal key uniquely linked to the signatory.
Allow for electronic identification of the signatory.
Make it possible to detect violations of the integrity of electronic data to which this signature is linked.

Use and incorporation remain in their sole control

The person using the secure electronic signature must have sole control over the means of creating the signature. Typically, this requires managing a key pair or two-factor authentication, with the signer holding the private key exclusively to prevent signature forgery⁸.

Being uniquely linked to the signer

A secure electronic signature must be uniquely connected to the person using it. The signature must be uniquely created with methods only the signer can access, like a private key and confidential information, to verify their identity.

Able to identify the person using the technological process

The process used to create the signature must be capable of identifying the person signing. This may include using a biometric signature, Personal Identification Number (PIN), email address, or company registration number.

Track down any alterations made after signing

It is essential to preserve the authenticity of the signed document. Modifications made to the document post-signature should be identifiable. This is commonly accomplished through an audit trail. Audit trails record the signer’s IP address, timestamps of key signing events, and location, providing proof of identity, timing, and signature place.

A qualified electronic signature (QES) is a type of electronic signature that is created using a qualified electronic signature tool and is based on a qualified public key certificate⁹. A qualified electronic signature has the same legal force as a handwritten signature and is presumed to correspond to a handwritten signature¹⁰. Additionally, QES must meet the following requirements¹¹:

A statutory compliant certificate at the time of signing¹².
A qualified trust service provider issued a valid certificate when signing¹³.
Signature validation data corresponds to the data provided to the relying party.
The unique set of data representing the signatory in the certificate was correctly provided to the relying party.
The use of any pseudonym is clearly indicated to the relying party if used at the time of signing¹⁴.
The electronic signature is of a qualified electronic signature creation device¹⁵.
The integrity of the signed data has not been compromised.
Meets the validity standards of an advanced electronic signature.

The authentication of the qualified electronic signature employs an asymmetric cryptographic system and a hash function, which is an algorithm that consistently generates a fixed hash result from an input record, making it computationally infeasible to reverse-engineer the original record or to have two different records to produce the same hash. Furthermore, the electronic record can be verified using the signatory’s public key, which, along with a unique private key, forms a functioning key pair exclusive to the signer.

Summary analysis

Law of Ukraine “On Electronic Trust Services” No. 2155-VIII as of 5 October 2017

Typex of eSignature	Unique features	Legal validity
Simple electronic signature (SES)	No unique feature apart from being in electronic form.	N/A
Advanced electronic signature (AES)	Created by means of cryptographic conversion of electronic data to which this signature is linked. Created by means of cryptographic conversion of electronic data to which this signature is linked. Created with the use of an advanced electronic signature device and a personal key uniquely linked to the signatory. Allows an electronic identification of the signatory. Allows the detection of any violations of the integrity of electronic data to which this signature is linked.	Validity is dependent on the evidentiary weight.
Qualified electronic signature (QES)	A statutory compliant certificate at the time of signing. A qualified trust service provider issued a valid certificate when signing. Signature validation data corresponds to the data provided to the relying party. The unique set of data representing the signatory in the certificate was correctly provided to the relying party. The use of any pseudonym is clearly indicated to the relying party if used at the time of signing The electronic signature is of a qualified electronic signature creation device. The integrity of the signed data has not been compromised. Meets the validity standards of an advanced electronic signature.	Deemed valid unless the contrary is proven. Bears the same validity standards as a handwritten signature.

Recognition of foreign electronic signatures in Ukraine

Electronic signatures provided in line with the requirements of regulatory acts that control the legal relations in the field of electronic signatures in foreign states are recognized in Ukraine as eSignatures of the same type if at least one of the following conditions is met¹⁶:

A qualified provider of eSignature is included in the Trusted List of the state with which Ukraine has concluded a relevant bilateral or multilateral international agreement.
A qualified provider of eSignature of a foreign state meets the requirements of the Law on Electronic Trust Services, which is confirmed by the central certification authority (or certification center in the case of providing electronic trust services in the banking system of Ukraine and when transferring funds).

Trust list of electronic signature providers in Ukraine

The Central Certification Authority is mandated with implementing, maintaining, and publishing on its official website a Trusted List¹⁷ containing information on qualified electronic trust service providers together with information on the qualified electronic trust services they provide. The trusted list must always be kept current, published securely, and include the electronic seal of the central certification authority in a format that computers can process automatically.

The following is the list of qualified Trust Service providers for cross-border usage¹⁸ in Ukraine¹⁹:

State Enterprise “Diia”
State Enterprise “Ukrainian Special Systems” (SE “USS”)
Joint-Stock Company Commercial Bank “PrivatBank” (JSC CB PrivatBank)
“Vchasno Service” LLC
Deposit Sign LLC
State Tax Service Of Ukraine
Joint Stock Company “First Ukrainian International Bank”
The General Staff Of The Armed Forces Of Ukraine
Joint Stock Company “Universal Bank”
ATS LLC.

The following is the list of qualified Trust Service providers within Ukraine²⁰:

Ministry of Digital Transformation of Ukraine
National Bank of Ukraine
Military unit 2428
Office of the Attorney General
General Staff of the Armed Forces of Ukraine
State Treasury Service of Ukraine
JSC “Market Operator”
State Enterprise “DIYA”
DP “USS”
State Tax Service of Ukraine
Ministry of Internal Affairs of Ukraine
Security Service of Ukraine
Foreign Intelligence Service of Ukraine
LLC “Key Certification Center “Ukraine””
LLC “Ilife”
LLC “Vchasno Service”
JSC “Pravex Bank”
JSC “Oschad Bank”
JSC Commercial Bank “Privat Bank”
JSC “UKRSIBBANK”
LLC “Art-Master”
LLC “INTER-METL”
Branch “GIOC” of JSC “Ukrzaliznytsia”
JSC “Sense Bank”
TOV “Deposit Sign”
JSC “Credit Agricole Bank”
JSC “First Ukrainian International Bank”
JSC “Bank Alliance”
Public Joint Stock Company Joint Stock Bank “UKRGASBANK”
JSC “TASKOMBANK”
LCC “AMO FINTECH”
JSC “Universal Bank”
Military Unit 3077 NGU
LLC “ATS”

The scope and limitations of the electronic signatures

Electronic signature transactions and their applications do not universally possess legal recognition for completing documents. Accordingly, certain categories of transactions and uses are appropriate for electronic signatures, whereas others are not. The following is an analysis of this issue, along with a summarized table of the transactions.

Documents that can be signed electronically

Electronic signatures can be employed to affix signatures and provide countersignatures on a diverse array of documents, such as:

Human resources
Procurement
Software license agreements
Insurance industry
Educational field
Commercial contracts
Non-disclosure agreements (NDAs), etc.

Permissible transactions through qualified electronic signatures (QES) only

Qualified electronic signatures are deemed to bear the same legal validity granted to wet-ink signatures. As such, the following can only be signed in either wet-ink signature or a qualified electronic signature:

Acts by State authorities, local governments, enterprises, institutions, and organizations of state ownership²¹.
Notarial agreements²²
Privately owned legal entities²³
Individuals filing electronic documents in court or reporting in electronic form to state authorities²⁴, etc.

Exempted transactions

Caution should be exercised when handling certain sensitive documents in Ukraine, which may require a handwritten signature for their execution. These exclusions typically include:

Certificates of inheritance rights
Unique identity documents such as passports and other identity documents, and death certificates
Wills and Trusts
Family law documents, such as marriage certificates and divorce agreements

Summary of the scope and limitations

Permissible transactions	Permitted through QES only	Transactions that may be exempted
Human resources Procurement Software license Agreements Insurance industry Educational field Commercial contracts Non-disclosure agreements (NDAs)	Acts by State authorities, local governments, enterprises, institutions, and organizations of state ownership. Notarial agreements Privately owned legal entities. Individuals filing electronic documents in court or reporting in electronic form to state authorities.	Certificates of inheritance rights. Unique identity documents such as passports and other identity documents, and death certificates. Wills and Trusts. Family law documents, such as marriage certificates and divorce agreements.

To guarantee the legitimacy of an electronic signature, it is recommended to adhere to the following best practices while also ensuring compliance with all relevant legal obligations:

Verify the identity of the person signing and, in companies, confirm that the individual is legally authorized to commit the company with their signature.
Obtain explicit consent from the person signing, which can be included in the contract itself or provided through a separate consent document, acknowledging their intent to use the chosen electronic signature method for the document.
Safeguard the document against any alterations post-application of the electronic signature.
Maintain a detailed record of the signing process, documenting each action performed by the person executing the signature.

How does BoldSign help

The following elements of compliance available within BoldSign can be used to comply with Ukraine’s electronic signature laws:

Secure and unique signing link: A secure and unique link to sign a document is sent directly to the signer’s email address. This ensures that the document is only accessed by the intended signer and cannot be tampered with.
Password protection: Senders can specify a password that needs to be entered before viewing and signing a document. This adds another layer of security to the signing process.
Audit trail: The IP address of the signer and timestamps for all significant events in the signing process are recorded in an audit trail. This provides a record of who signed the document, when, and where.
Digital signature: The final document is digitally signed with an AATL-compliant certificate. This ensures that the document cannot be tampered with without invalidating the signature.
Consent: Signers are asked to confirm their intent to sign electronically and informed that they could opt out. This ensures that the signer is aware of the implications of signing electronically and has given their consent.
Custom terms: Get your signers to agree to a custom set of terms. This can be useful to ensure additional security or that the signer understands the terms of the document.

Disclaimer: The information on this page is intended to help businesses understand the legal framework of electronic signatures for this particular country.

However, Syncfusion’s officers, directors, stockholders, affiliates, attorneys, accountants, employees, or agents cannot provide legal advice. You should consult your personal attorney regarding your specific legal questions. Laws and regulations are subject to frequent changes, and the information may not be current or accurate. To the maximum extent permitted by law, Syncfusion provides this material on an “as-is” basis. Syncfusion disclaims and makes no representation or warranty of any kind with respect to this material, express, implied, or statutory, including representations, guarantees, or warranties of merchantability, fitness for a particular purpose, or accuracy.

Syncfusion makes no warranties of any kind, including but not limited to the information or the product, whether express, implied, statutory, or otherwise. To the maximum extent permitted by law, Syncfusion disclaims all conditions, representations, and warranties, whether express, implied, or statutory, with respect to this information, without limitation of any implied warranty of merchantability, fitness for a particular purpose, accuracy, or currentness of this information.

Syncfusion nor its officers, directors, stockholders, employees, affiliates, attorneys, accountants, or agents shall be liable for indemnification, nor does this create an express or implied, contractual or statutory, equitable or otherwise, under this agreement. The officers, directors, stockholders, affiliates, attorneys, accountants, or agents will not have any liability in any form.

¹ Law of Ukraine “On Electronic Trust Services” No. 2155-VIII as of 5 October 2017; Article 18(4) https://zakononline.ua/documents/show/377015___685643.
²Code of Ukraine No. 435-IV dated January 16, 2003 Civil Code of Ukraine. https://zakononline.ua/documents/show/234444___672767.
³ Law of Ukraine “On Electronic Trust Services” No. 2155-VIII as of 5 October 2017; Article 18(3). https://zakononline.ua/documents/show/377015___685643.
⁴Ibid., Article 17(3).
⁵Ibid., Articles 1(9) & 1(12).
⁶Ibid., Article 15(2).
⁷Ibid., Article 1(44).
⁸Ibid., Article 15(2) p. 3.
⁹ Law of Ukraine “On Electronic Trust Services” No. 2155-VIII as of 5 October 2017; Article 1 (23). https://zakononline.ua/documents/show/377015___685643.
¹⁰Ibid., Article 18(4).
¹¹Ibid., Articles 18 (1) & 18(2).
¹²Ibid., Article 18(6).
¹³Ibid., Article 23.
¹⁴Ibid., Article 23(4).
¹⁵Ibid., Article 19.
¹⁶Law of Ukraine “On Electronic Trust Services” No. 2155-VIII as of 5 October 2017; Article 38. https://zakononline.ua/documents/show/377015___685643.
¹⁷Ibid., Article 35.
¹⁸Trusted List with the List of QTSPs for Cross-border Use of TS. Accessed April 1, 2026. https://czo.gov.ua/en/trustedlist/3
¹⁹Trusted List in Ukraine.” Central Certification Authority. https://czo.gov.ua/en/trustedlist.
²⁰Trusted List: Trusted list with the list of QTSPs for the use of TS within Ukraine. Central Certification Authority. Accessed April 1, 2026. https://czo.gov.ua/en/trustedlist/2.
²¹Law of Ukraine “On Electronic Trust Services” No. 2155-VIII as of 5 October 2017; Article 17 p.3.685643-https://zakononline.ua/documents/show/377015
²²Ibid., Article 17.
²³Ibid., Article 17.
²⁴Ibid., Article 17.

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