The European Commission adopted Implementing Regulation (EU) 2026/248 to standardise the formats of advanced electronic signatures and seals that public sector bodies must recognise. For companies operating in Poland, this means checking whether their signing and validation tools will remain technically acceptable in dealings with public administration and in cross-border workflows.
The regulation was adopted under Articles 27(5) and 37(5) of eIDAS. Its purpose is to ensure that Member States recognise specific technical formats for advanced electronic signatures and advanced electronic seals when these are required for online public sector services. At the same time, it repeals Implementing Decision (EU) 2015/1506.
A transitional model is built into the regulation. The technical specifications in Annex I are to apply from 23 February 2027. The legacy specifications in Annex II remain recognisable only for signatures and seals created before 23 February 2028. In practice, companies need to verify not only that they can create electronic signatures, but also that these signatures and seals are created and validated in a format recognised by public sector bodies.
The regulation also allows recognition of other formats, but only where a Member State provides free online validation methods. These methods should, where technically feasible, support automated processing, be clearly documented and indicated within the signed document or container, and confirm certificate validity at the time of signing or sealing, data integrity and proper identification of the signatory.
From a business perspective, the impact is strongest in administrative and cross-border document flows. Companies using signing platforms, internal PKI solutions or trust services across multiple EU jurisdictions should assess whether their current validation methods will remain acceptable once the new framework becomes operational.
What this means for our clients
- Ask your trust service or signing provider whether supported formats align with the new specifications and transition dates.
- Review workflows involving public sector submissions, especially those using automated signatures or seals.
- In cross-border projects, confirm whether validation methods will be accepted across jurisdictions.
- Run technical tests before 23 February 2027 instead of relying on live production documents.
Regulation 2026/248 does not change the core concept of eIDAS, but it tightens the technical rules around recognition and validation. We can support with a focused readiness review covering signature formats, validation methods and operational risk.