Electronic signatures in the United Arab Emirates

What the law says

Federal Decree-Law No. 46 of 2021 on Electronic Transactions and Trust Services came into force on 2 January 2022 and repealed Federal Law No. 1 of 2006. An electronic document does not lose its legal force or enforceability for being electronic (Article 5), and a contract does not lose its validity, evidential weight or enforceability merely because it is made in the form of electronic documents (Article 10).

Where a law requires a signature, Article 8 treats the requirement as met by a means that identifies the person and indicates their intention with respect to the information in the document, if that means is fit for the purpose for which the document is created or sent, or does so alone or together with other evidence. Under Article 28, a person may use any form of electronic signature unless the legislation in force provides otherwise.

The Decree-Law has three tiers. An electronic signature identifies the signatory and their approval of the document, and its admissibility as evidence is not precluded because it is in electronic form (Article 18). A reliable electronic signature (Article 19; "advanced" in the TDRA's translation) is also linked to and under the full and exclusive control of the signatory, and detects any change to the signed data, as the Executive Regulation specifies. A qualified electronic signature is a reliable one created on a qualified signature device and based on a qualified certificate, and only it is equal to a handwritten signature in authenticity and legal effect (Article 18(3)).

The Executive Regulation is Cabinet Resolution No. 28 of 2023. The DIFC and ADGM financial free zones have their own rules: the DIFC Electronic Transactions Law (DIFC Law No. 2 of 2017) and the ADGM Electronic Transactions Regulations 2021.

The laws that apply

• Federal Decree-Law No. 46 of 2021 on Electronic Transactions and Trust Services: Articles 5, 8 and 10 (legal effect), 18 to 20 (the three tiers of signature), 2(2) (the Cabinet may exclude transactions), 28 (any form unless the law says otherwise).
• Cabinet Resolution No. 28 of 2023: the Executive Regulation: technical requirements, trust service providers, qualified signatures and certificates.
• DIFC Law No. 2 of 2017 and the ADGM Electronic Transactions Regulations 2021: electronic transactions inside the two financial free zones.

Where an electronic signature is not enough

Unlike the 2006 law it replaced, the Decree-Law has no list of excluded transactions. The Cabinet may add, delete or exclude transactions under Article 2(2), and any law that asks for a particular form still applies (Article 28).

The 2006 law excluded personal status matters such as marriage, divorce and wills, title deeds to immovable property, negotiable instruments, sales, purchases and leases of immovable property for more than ten years, and documents that must be attested before a notary. The 2021 Decree-Law does not repeat that list, but the laws on those matters may still require a particular form, an official procedure or a qualified signature. Check them before relying on an electronic signature.

In Dubai, tenancy contracts must be registered through Ejari, the Real Estate Regulatory Agency's system. Signing electronically does not replace that registration.

What PQC Imza is, and what it is not

In the UAE, a PQC Imza signature is an electronic signature under the Decree-Law: it identifies the signer, from the chip in their passport or ID card, and records their approval of that exact file. It is not a qualified electronic signature: it is not made on a qualified signature device or based on a qualified certificate, so it does not have the handwritten-signature equivalence of Article 18(3). PQC Imza is not a UAE trust service provider.

PQC Imza is an electronic signature service. Each signature is made on the signer's phone with ML-DSA, the post-quantum signature standard NIST published in 2024 (FIPS 204), and is bound to the exact file that was signed. Signers verify their identity in the app by reading the chip in their passport or ID card, and every signature records how its signer was identified.

It is not a qualified, certified or government-accredited digital signature, and PQC Imza is not a licensed or accredited certification authority in any country. Where a law asks for that kind of signature, or for a handwritten signature, a notary or registration, use what the law asks for.