Qualified Electronic Signature: Mandatory or Just a Misunderstanding?

From November 1, 2025, the AVDH (Document Authentication Based on Identification) service has been discontinued. As a result, the official position is that every representative of a business entity must have a qualified electronic signature for electronic administration.

What is the official position?

Government employment agencies only accept documents signed with a qualified or qualified certificate-based advanced electronic signature. The FEDOR service, which replaced AVDH, does not create a fully legally binding private document and does not verify representation rights. Although the DÁP eSignature is technically capable, several authorities claim it is only suitable for personal use.

Professional debate: Is a qualified signature really mandatory?

Several professional organizations argue that the DÁP eSignature can be used for business purposes, as no legislation explicitly prohibits it. A legal dispute is currently underway, which may also affect the interpretation of “corporate signature.” The root of the problem is that Hungarian law does not clearly define “corporate signature,” so authorities often act based on their own interpretation.

According to the advisory board of the Curia (Hungarian Supreme Court), an advanced electronic signature (AES or FES) also qualifies as a fully legally binding private document, so a higher-level qualified electronic signature (QES) is not necessarily required.

Recommended providers according to the official position

👉 If someone wants to play it safe and avoid disputes or conflicts with authorities, it is advisable to choose a qualified electronic signature listed in official communications. This ensures that all authorities will accept the signed documents.

Free and low-cost alternatives

However, if one is not afraid of legal interpretation disputes and potential inconveniences, it may be worth exploring alternative solutions, especially those offering advanced electronic signatures, even for free or at a low monthly cost.

Several services on the market offer advanced electronic signatures, either free or for a few euros per month:

  • ittirdala.hu – Hungarian-language service using GoodID identification, with 5 free signatures.
  • Yousign – 2 signatures/month free, with AES/QES extension.
  • Zoho Sign – 5 documents/month free.
  • SignRequest – 10 documents/month free.
  • Xodo Sign (eversign) – 3 documents/month free.
  • SignWell – 3 documents/month free.
  • Smallpdf eSign – free with daily limit.
  • Jotform Sign – 10 signed documents/month free.

Practical examples of electronic administration

Electronic signatures are becoming indispensable in more and more areas. Here are some practical examples:

  • Applying for employment subsidies: e.g., submitting GINOP Plus applications, where documents attached via the ePapír system must be signed in advance.
  • Declarations submitted to the tax authority (NAV): e.g., requests for advance tax modifications, notifications requiring authenticated documents.
  • Communication via the Company Gateway (Cégkapu): e.g., responses to official inquiries, official statements that must be signed before submission.
  • Participation in public procurement procedures: authentication of tender documentation.
  • Payroll documents: e.g., employment contracts, amendments, notifications authenticated with electronic signatures – while these are not considered electronic administration on their own, if submitted electronically to an authority (e.g., as part of a subsidy application), they become part of the electronic administration process.

What can a business entity do?

  • Check whether the representative has the appropriate signature.
  • If not, choose a reliable provider – even a free one.
  • Consider registering the certificate in the company register to verify representation rights.
  • Monitor the development of the legal dispute, as the business use of the DÁP eSignature may still change.

Final thoughts

The regulation and practice surrounding qualified electronic signatures currently offer multiple interpretations. The official position is clear, but professional debates and alternative technical solutions are also gaining ground. Business entities should consider whether legal certainty or flexibility is more important to them and choose from the available options accordingly.