Electronic Signatures in Official Environments

Dr. Kósa Ferenc ügyvéd, a Magyar Elektronikus Aláírás Szövetség (MELASZ) elnöke
We have gained something, but also lost something — the DÁP app has introduced electronic signing capabilities, while the simple e-signature service offered by AVDH has largely been discontinued. 2025 brings major changes in electronic authentication, and every business organization must start preparing for them.

 

◼︎ Changes in Electronic Signatures

Many were unpleasantly surprised when, at the beginning of January, the often-used government electronic service, the AVDH (Identification-Based Document Authentication), became unavailable due to its discontinuation. „Despite prior extensive communication about the shutdown of AVDH, many were still caught off guard,” says Dr. Ferenc Kósa, President of MELASZ.

As expected in Hungary, some loopholes were quickly found: AVDH remained available for certain processes requiring online form submissions and could still be used via the ePapír (epapir.gov.hu) service by initiating a case and attaching documents to be authenticated.

Everyone Will Need It

However, there is a major issue: In many cases, this workaround is no longer legally sufficient. Since January, according to Hungary’s civil procedural law, documents signed with AVDH are not accepted as fully probative private documents. „It’s as if the document was not signed at all. Such documents cannot be used as submissions in civil court proceedings,” explains Dr. Kósa. Many lawyers and even judges are only now realizing that their submitted or accepted documents are invalid.

The only solution is to obtain a qualified electronic signature from the market for authenticating documents and submissions. (We’ll soon explain why the DÁP app’s electronic signature cannot substitute this.)

This alone is a significant disruption, but even greater changes are ahead. Although AVDH remains temporarily usable for integrated form authentication, this option will expire on October 31, 2025. From November 1, 2025, all business organizations — including sole proprietors, associations, and foundations with a tax ID — must use market-sourced qualified electronic signatures.

Signing or Authorizing

These changes will certainly impact companies’ internal processes, necessitating significant adjustments. The old practice — where a company executive would simply hand over their Ügyfélkapu (Client Gateway) login credentials — will no longer be valid. Going forward, a declaration will only be legally binding if electronically signed by the authorized company representative themselves.

Thus, management will have two options:

  • Retain signing rights: Other departments (accounting, legal, etc.) can draft electronic documents, which are then reviewed, approved, and signed by the authorized person.
  • Delegate signing rights: Management may formally authorize, for example, two employees from the finance department to act jointly in specific cases. From then on, these individuals could electronically sign and submit, for instance, tax returns, provided both signatures appear on the document. A formal power of attorney must be submitted to the tax authority (NAV) to validate this delegation.
Is an Electronic Signature Worth It?

A corporate qualified electronic signature is not as costly as many fear. There are Hungarian solutions available at a promotional price of around 60,000 HUF net (approx. 200 EUR) for three years, translating to less than 2,000 HUF (around 6 EUR) per month. More expensive services can cost around 10,000 HUF monthly.

Comparatively, printing a single page costs about 20 HUF net, and postal services cost several hundred HUF per mailing. Thus, switching to electronic signatures can quickly offset costs while enabling the full digitalization of official correspondence and contract management.

DÁP Is for Personal Use Only

Returning to the DÁP app’s built-in e-signature: why isn’t it suitable for official, corporate, or professional use? The DÁP-based signature was established under the EU’s eIDAS regulation, which states — in admittedly convoluted language — that digital signatures provided free of charge by member states through digital wallets are only for natural persons and for personal purposes.

This means DÁP signatures cannot be used:

  • By legal entity representatives,
  • When acting on behalf of another person,
  • For professional or business purposes.

Thus, lawyers cannot use it for client representation, and sole proprietors cannot use it for business-related interactions with the government. Future improvements, such as attribute certificates, may allow attaching additional certification to an e-signature, proving that the signer is acting in an official capacity. However, these certificates will not be free and will not be granted automatically.

The same restrictions apply to the two private-sector providers in Hungary offering free personal-use electronic signatures. While providers cannot see what is signed, they can monitor usage patterns. If a personal-use certificate is used excessively (e.g., dozens of times per month), providers may investigate and revoke the certificate for unauthorized professional use.

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