Individuals and legal entities are no longer required to use a Qualified Electronic Signature (QES) stored in a secure environment (token) to access electronic services. Shortly before the New Year, the Cabinet of Ministers of Ukraine adopted a resolution regulating this matter.
Resolution No. 1298, which entered into force on December 31, 2023, establishes the technical requirements for creating and verifying Advanced Electronic Signatures or Seals. These are signatures stored on an unsecured medium in the form of a regular file. From now on, they may be used on a permanent basis unless otherwise provided by law.
Previously, Advanced Electronic Signatures and Seals were used temporarily within the framework of pilot projects introduced during martial law. However, it is now possible to replace a QES with an AES permanently.
This change will simplify the acquisition of electronic signatures, facilitate the signing of electronic documents, and harmonize Ukrainian legislation in the field of electronic trust services with European standards. It is possible that further steps toward European integration will eventually lead to the complete replacement of QES with more flexible alternatives.
At this point, it is important to explain the difference between an Advanced Electronic Signature (AES) and a Qualified Electronic Signature (QES). This is particularly relevant because many people have become accustomed to referring to all electronic signatures as “QES.” In practice, however, there are significant technological and legal differences between the two.
The familiar Qualified Electronic Signature (QES) is an electronic signature stored on a secure device (usually a dedicated hardware token). Such devices are commonly referred to as “tokens.” These signatures are based on a qualified public key certificate and cannot be created online. To obtain a QES, the applicant must personally provide the required documents to a qualified trust service provider. Online authentication is not available for this process.
In addition, a QES may only be stored on a cryptographically protected device. A list of approved devices can be found on the website of the State Service of Special Communications and Information Protection of Ukraine. In most cases, these are secure USB tokens used exclusively for storing the signing key.
In contrast, an Advanced Electronic Signature (AES) is a file-based signature that can be stored on a USB drive or directly on a computer and can be generated online. As a result, it is significantly more convenient both to obtain and to use.
This means that since the beginning of 2024, the transition to electronic document management has become much easier for Ukrainian citizens and businesses. At the same time, organizations that prefer to continue using QES for their own reasons—such as maintaining a higher level of security—may still do so.
