Lobbying Activity
Response to Digital package – digital omnibus
14 Oct 2025
Docusign welcomes the European Commissions ambition to introduce a Digital Omnibus as part of a broader digital package to simplify the EU digital rulebook by reducing administrative costs, harmonising requirements, and increasing legal certainty for businesses without weakening user protections. The Commissions call for evidence rightly focuses on targeted adjustments in the data acquis, cybersecurity incident reporting, the smooth application of the AI Act, and legal clarity for the European Digital Identity Framework, including alignment with the forthcoming EU Business Wallet. We strongly support these objectives, particularly in the areas of data, AI, and digital identity, where simplification can deliver real benefits for businesses and users alike. As the leading provider of electronic and digital signature solutions and intelligent agreement management, and a qualified trust service provider (QTSP) in the EU, Docusign is committed to working closely with the European Commission, Member States, supervisory authorities, and industry partners to make this vision a reality. We look forward to contributing practical insights and solutions that help the Digital Omnibus reduce regulatory duplication, harmonise expectations, and strengthen legal certainty for all actors in the digital and identity ecosystem.
Read full response13 May 2025
This Implementing Act, which establishes a crucial link between the Identity Proofing process and the subsequent signing certificate or attribute attestation, represents a foundational element for ensuring the integrity and trustworthiness of any workflow or transaction. Docusign welcomes this Implementing Act and its associated standards, as they will govern the reliance of EU member states on end-user identity validation specifically, and foster trust more broadly. Furthermore, Docusign commends the overarching approach of this Implementing Act and its related standards for embracing novel technologies in Identity Proofing and supporting innovation within this domain. It is imperative that such advancements also incorporate robust defenses against cyber threats at this critical stage of Identity Proofing.
Read full responseResponse to Provision of qualified electronic time stamping services
13 May 2025
Docusign observes that this Implementing Act, by imposing restrictions exceeding the requirements encompassed by the EN 319 421 ETSI standard, presents adoption hurdles for service-oriented technologies. Specifically, the requirements in the accompanying Annex, section 1(6) regarding Time Stamping Unit (TSU) key generation part TIS-7.6.2-06, limit the standard's flexibility. Service-oriented technologies often require robust redundancy through seamless substitution of failed TSUs with identical replacements, necessitating secure replication of TSU signature keys across multiple units. From a compliance perspective, we anticipate that service auditors will mandate strict adherence to this act, potentially impeding approval of otherwise secure services due to these new limitations. This raises the question of the rationale behind applying such stringent restrictions to Secure Timestamping while comparable services like Certificate Creation Services face no such limitations.
Read full responseResponse to Management of remote qualified signature creation devices as a qualified trust service
13 May 2025
Docusign acknowledges and supports this draft Implementing Act. Being a prominent provider of cloud agreement and remote e-Signature platforms, Docusign advocates for the utilisation of all signature modalities required by applicable geographic and industry-specific regulations. The adoption of remote Qualified Electronic Signatures and remote Qualified Electronic Seals holds particular importance for the EU. Consequently, the establishment of clear guidelines, exemplified by this Implementing Act and its associated technical standards, is crucial for maintaining harmonised cross-EU market solutions as the prevalence of remote signatures and seals expands in the future.
Read full response