The first pilot in the European Union offering free one-time qualified signatures!
At the end of October 2025, a pilot of qualified signatures in the mObywatel app was launched and made publicly available. This is another very important step in the digitalisation of the Polish economy, and a demonstration that cooperation between public administration and the commercial sector — for the benefit of citizens — is possible. The new change gives everyone access to five free, secure, and convenient qualified signatures per month, usable on any PDF document. All you need is an active mObywatel app, an identity card with an electronic layer, and to choose one of the five Polish QTSPs operating on the market. Additional signatures are also available, but for a fee.
Why is using a qualified signature so important?
The qualified signatures process in mObywatel addresses several barriers that previously discouraged individual users. From the perspective of digital market development, this creates a real opportunity to popularise this solution. Qualified signatures have the same legal effect as handwritten signatures and allow almost all official and private matters to be handled electronically using a single tool.
Who regulates the validity of qualified signatures?
The validity of qualified signatures is regulated at the European level by the eIDAS Regulation, and in Polish law by the Civil Code. As a result, their effectiveness and legal validity do not require any additional approvals, contracts, or specific tools.
In the long term, enabling users to create qualified signatures is planned as a mandatory feature of the European Digital Identity Wallets across the entire European Union. This change stems from the amended eIDAS Regulation (commonly referred to as eIDAS 2.0). By the end of next year, all EU Member States are obliged to implement and provide these wallets to their citizens, with one of their key functionalities being the ability to generate free qualified signatures for private use.
As stated in Article 5a of the revised eIDAS Regulation:
“[…] European Digital Identity Wallets […] shall offer all natural persons the ability to create qualified electronic signatures by default and free of charge […], and Member States […]may provide for proportionate measures to ensure that the use of qualified electronic signatures free-of-charge by natural persons is limited to non-professional purposes. […]”.
This means that every EU citizen will gain access to a tool with the same legal force as a handwritten signature — and when used for non-professional purposes, without bearing the associated costs. It is an ambitious and innovative approach to developing the digital services market across the European Union, but it also raises an important question: what exactly counts as non-professional use?
What does non-professional use of a qualified signature mean?
If an individual uses an electronic signature for purposes other than running a business or performing powers of attorney on behalf of commercial or administrative entities, the service should be free of charge.
Importantly, generating an electronic signature is, by default, a trust service delivered for a fee. It requires both technical and legal support for the signer and for the relying party receiving the signed document. For this reason, each electronic signature must have an identified payer who covers the cost of its issuance. This may be the state treasury or a commercial entity.
Determining who bears the cost of electronic signatures used for non-professional purposes also requires identifying the party initiating the signing process and defining the signing requirements.
For example, the requesting party may be:
- a public administration service issuing a form that requires a signature,
- a bank requesting a signature for a credit agreement.
In both cases, the requesting party is a professional entity that expects the signature to be created in a specific manner. In such a situation, even though the signature is placed by a private individual (and is thus free for them), the cost is borne by the professional party.
This approach eliminates the need for overly detailed definitions of professional versus non-professional use. It creates a simple, logical distinction grounded in real business practice. There will always be edge cases or attempts to avoid paying for signatures, but this model enables a clean, elegant, and universal framework for attributing the cost of qualified signatures generated from the wallet.
Why is the pilot of free one-time qualified signatures such an important step in the development of the mObywatel application?
- It provides an opportunity to gain experience and prepare for the full implementation of this service in the eIDAS-compliant version of mObywatel. Notably, qualified signatures are being tested in Poland much earlier than required by the official eIDAS rollout schedule. This gives time to collect feedback from users, partners, and institutions, verify technological, business, and legal assumptions, and make necessary adjustments.
- It also establishes a foundation for market collaboration between public administration and commercial trust service providers. This is a crucial element in building the entire ecosystem; it enables the delivery of the best possible solutions to citizens and supports compliance with eIDAS. It also protects the competitiveness of Polish providers, both locally and in the European market.
- Finally, it is the first real step towards the widespread adoption of qualified signatures. Making them available in a simple, intuitive form within an app already used by over 11 million citizens significantly increases the likelihood of mass adoption and the development of digital skills. This, in turn, will stimulate the growth of future digital services and products.
Publication date: 18.11.2025