An article by Dr. Christiane Bierekoven, Philip Bazin and Tomasz Kozlowski

E-signature_Article_published_version.pdf

This article presents some significant issues on the recognition of electronic signatures with regard to foreign certificates from the perspective of German, French and Polish law.

The European Union legislation applies to Germany and France, and has served as a guide for Polish legislation in the course of preparations of the accession of Poland to the European Union.

There are therefore strong similarities between the legislation of these countries, but as the French example shows, the results may also differ with regard to the material law applicable to a contract.

The difference between simple and advanced electronic signature is discussed within the context of French law.

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