Comparison of Electronic Signature between Europe and Japan: Possibiltiy of Mutual Recognition

Abstract

electronic signature is one of the most used trust services and should be mutual recognized. This study compares legal framework, audit scheme and audit criteria of electronic signature between Europe and Japan and identified deviations to examine the possibility of mutual recognition. Also, definition of trust services usually includes other than electronic signature such as timestamps and electronic deliveries but because electronic signature is only one trust service which legal admissibility is defined by law in Japan, the paper is focused on electronic signatures.