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Progress on the European Electronic Signature Directive, which is at the heart of Europe's e-commerce strategy, has been patchy, with some countries forging ahead, while the rest trail behind.
The directive should have been implemented in June, but only Germany and Austria have operational schemes, the European Forum for Electronic Business revealed last week.
"The other member states are either still waiting or the legislation is only partly ready. Some states are still establishing what strategy they should adopt," said the group's legal working group chairman Jos Dumortier.
The forum is concerned that countries are interpreting the directive in different ways, raising potential barriers to companies that want to use digital signatures across Europe.
Germany is asking certification authorities to meet stiffer security tests than the regulatory regimes in the rest of Europe, including the UK's T-Scheme, which accredits certification authorities.
"If you are a company in the UK and you want to develop operations in Germany, with T-scheme accreditation it will be difficult for you to enter the German market," said Dumortier.
Countries are also taking different approaches to the levels of liability that certification authorities will have to meet in the event of a security breach.
Liability levels are low in the UK but significantly higher in Germany, Finland and Spain. Spanish companies are required to take out liability insurance equivalent to 4% of their annual certificate sales.
Italy, Holland, Belgium and Austria are planning to issue their citizens with digital signature chip cards. Finland has already issued 10,000 cards to its population on a voluntary basis. They will allow people to access government services online.
However, other countries, including the UK, have no plans to issue chip cards.