eIDAS and Declarations of Conformity — signature claims and evidence

Under eIDAS Article 25(1), an electronic signature is not denied legal effect solely because it is electronic or non-qualified. Only a qualified electronic signature has the express handwritten-equivalent effect under Article 25(2). Advanced signatures require the distinct Article 26 conditions; a displayed name, uploaded image or hash alone does not establish them.

What the current Cenitia workflow provides

The built-in workflow records typed/drawn/uploaded simple electronic signatures and explicit review notes. Sections and product identity are frozen; the stored PDF has a write-once archive path and SHA-256 integrity record. This does not provide PAdES cryptographic signing, a qualified certificate or PDF/A validation. PDF generation may fail independently of signing and is reported as unavailable until a successful archive is created.

For an external advanced/qualified signature, retain the signed original and validate the trust-service certificate, applicable status and signature evidence through the selected service. Do not claim an arbitrary phone or wallet is automatically a qualified signature-creation device.

Evidence to keep with the product

Record the intended purpose, responsible economic operator, target market, first placing date and exact hardware/firmware configuration. For each applicable requirement, link the actual test or assessment record, dated standard/specification, scope and reviewer decision. Proposed controls and supplier marketing statements are not evidence that the final configuration has passed an assessment.

Separate an open question from a completed assessment. A report outside the laboratory's relevant scope, a different firmware build or an unverified exemption needs a reasoned decision before it supports a declaration. Keep original evidence and the issued declaration alongside any AI-assisted working draft.

Using Cenitia for this work

Cenitia assists with a limited regulatory catalogue and draft documents. The manufacturer must confirm applicability, actual applied specifications and completed assessment procedures. AI scores are quality signals, not a probability of conformity. Source monitoring raises a review prompt when validated source text changes; it does not automatically verify amendments, update the corpus or monitor every national rule and OJ standard edition. Public QR verification records issuance, not product certification.

Review status

This guide was substantively corrected by Cenitia on 2 October 2026 using the primary references below. It is an editorial summary, not an authoritative legal quotation or an independently signed expert opinion. Product-specific and licensed-standard questions remain subject to a real technical review.

Primary references

• Primary source 1