WG 3.2 Electronic signature - BESTPRAC

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Ljubljana Meeting 6.3.2015

WG 3.2

Electronic signature

Ludivine BONADEI Carla MAZUHELI-CHIBIDZIURA

Chelo MORAN SAGREDO

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1. Implementation of the electronic signature in our institutions

1.1 Conditions of the electronic signature in H2020

1.2 Implementation by different institutions

1.3 Electronic-only submission of FP7 Forms C

2. Status/validity of the electronic signature in H2020

2.1 EU legislation

2.2 Validity of the electronic signature in H2020 projects

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1. Implementation of the electronic signature in our institutions


1.1.1 General conditions of the implementation of the electronic signature on the Participant Portal

1.1.2 Process of electronic signature on the Participant Portal

1.2 Implementation by different institutions

1.2.1 Case studies of implementation in France

1.2.2 Case studies of implementation in Spain

1.2.3 Case studies of implementation in Austria

1.3 Electronic signature of FP7 projects

1.3.1 The process of switching to electronic-only process

1.3.2 The documents concerned

1.3.3 Special clause 10 – Linked third parties

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Quick reminder on different stages of a project proposal

Time to grant from deadline 8 months:

5 months from the final date for submission

3 months from the date of informing successful applicants.

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1.1 Conditions of the electronic signature in H2020 1.1.1 General conditions of the implementation of the electronic signature on the Participant Portal 1.1.2 Process of electronic signature on the Participant Portal for a given project

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1.1.1 General conditions of the implementation of the electronic signature on the Participant Portal

• No more hard copies. • All signatures are electronic.

• Three requirements:

Identity of the signatory

Integrity of the signed document

Non repudiation

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1st requirement: The identity of the signatory • A chain of trust

1. One person is appointed by the Legal Representative in a formal process using blue ink signature = Legal Entity

Appointed Representative (LEAR) 2. To do this fill in the following documents:

• Appointment letter (signed by the authorised legal representative) • “Roles and duties” (signed by the authorised legal representative and by the LEAR) • Terms and conditions of use of the Participant Portal exchange system • Declaration or consent to the terms and conditions of the participant portal (signed by the authorised

legal representative) 3. Sent these forms together with the following documents:

• Official proof of identity for the legal representative and the LEAR • Document(s) proving that the legal representative appointing the LEAR is empowered as such.

4. Activate the LEAR’s online user account (LEAR`s username by e-mail and PIN Code is received by post)

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2d requirement: The integrity of the signed document

• Digitally sealed PDF document containing:

o Full content of the transmitted document o Set of metadata: certified time stamp, ECAS credentials of the actors in the

transaction…

• Digital seal is an advanced electronic signature, using public-private key mechanism

• Insures integrity of information: any attempt to change leads to break of the signature

• Is stored in the project archive for access at any time by all actors in the project

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3rd requirement: The non-repudiation

• Identity and access management using ECAS and the chain of trust

• Digital signature issued by a third party, containing metadata of the transaction (credentials of users, third party certified time stamp)

• Transparency (digital project archive) for all parties involved

• Terms of use for the secured electronic exchange system to be confirmed by all users (in particular on keeping ECAS credentials secretly)

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1.1.2 Process of electronic signature on the Participant Portal for a given project

- For a given project and a given beneficiary, Participant Contacts of the beneficiary or

Coordinator Contacts select LSIGN and FSIGN from the list established by the LEAR = PLSIGN & PFSIGN

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• Declaration of Honour – Before the GA can be signed, the PLSIGN of each beneficiary must sign a declaration of honour

(« grant declaration » in the system)

• Grant agreement signature – The EC prepares the GA for signing. Is is a pdf document, digitally sealed to guarantee its security,

reliability and authenticity.

– The coordinator’s PLSIGN signs the GA electronically.

– The system creates a new pdf document: digitally sealed by an external authority, including a time stamp and the signatory’s ECAS credentials.

– The EC signs the grant agreement

– Participants’ PLSIGNs sign the Accession forms (up to 30 days after the GA is signed).

– The GA enters into force on the day of the last signature.

– Linked third parties do not sign.

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1.2 Implementation by different institutions 1.2.1 Case studies of implementation in France 1.2.2 Case studies of implementation in Spain 1.2.3 Case studies of implementation in Austria

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1.2.1 Case study of implementation in France: UTSLE3 1.2.1.1 Organizational Structure

President

Vice-President research

Department of research laboratories support

Grant office deals with all

research contracts (including H2020)

Financial office

European office deals with

educational projects

(is currently being integrated to the

Grant office)

International relations office

Vice-President international relations

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1.2.1.3 Electronic signature processing

No more paper version. Electronic-only signature.

Declaration of honour/Grant Agreement accession form:

UPS grant office follows-up the grant preparation

Once the Declaration of Honour is ready, LEAR + PLSIGN liaise and agree on the go/no

go for the signature

PLSIGN logs in to ECAS with her own credentials and signs

Printed version of the electronically signed document is recorded in the file

Form C:

Signature on the DRAFT Form C before online signature (in FP7 projects)

Original signed document is kept in the Research Service’s files

Documents are signed online by the FSIGN with her own account and credentials

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1.2.1.4 Electronic signature processing in France

• Comparisons made with other French institutions

– LSIGN may be the President of the university himself

– Its credentials for ECAS may sometimes be shared with the grant office

• The grant office manages the electronic signatures on behalf of the President

• This should not happen, for the EC indicates clearly that credentials are personal

– Adequate delegated signing authority may be given to an authorised LSIGN different from the President

– Paper signed version may still be produced within some universities when the electronic process differs from the previous paper process, which is compliant with the guidelines of the EC:

"If the internal rules of an organisation require more than one signature, this requirement must be implemented by establishing an internal process in the organisation assuring that the single electronic signature act in our system is executed only after all the necessary authorisations were given. These authorisations (signatures) must be collected, stored and archived locally following the usual management practice of the organisation, for instance via an internal paper-based process. Please refer also to the Terms and conditions of use of the electronic exchange system, stating that "The LEAR and its organisation warrant that users appointed as LSIGNs or FSIGNs are duly authorised to represent the organisation in relation to all LSIGN or FSIGN responsibilities". (see FAQs on the Participant Portal)

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VICE-PRESIDENT OF RESEARCH

Assistant to the Vice-President for research issues

Assistant to the Vice-President for the Science Park

TECHNOLOGY TRANSFER OFFICE OTRI

RESEARCH SERVICE Management of research

(in all phases)

SCIENCE PARK Transfer and comercialization

of results

1.2.2 Case study of implementation in Spain: UC3M

1.2.2.1 Organizational Structure

PRESIDENT

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Declaration of honour/Grant Agreement accession form:

1. UC3M prints document which it is signed on paper by the Vice-President of Research (LSIGN)

2. Original signed document is kept in the Research Service’s files

3. Documents are signed online through the President’s account

Form C: 1. Signature on the DRAFT Form C before online signature (in FP7 projects)

2. Original signed document is kept in the Research Service’s files

3. Documents are signed online through the President’s account

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Plan for Scientific and Technical Research and National Innovation

(our “H2020 “ programme)

• https://sede.micinn.gob.es site to acces to call for proposals and electronic management of projects

• The Ministry of Economy and Competitiveness recognized the legal representative for the institution

• Electronic signature is associated to the legal representative in the institution

• Electronic signature is made using an identity card

• Advanced electronic signature systems, including those based on recognized electronic certification, accepted by the Public Administrations

1.2.2.4 Electronic signature processing in Spain

https://sede.micinn.gob.es/

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LEAR

FSIGN

LSIGN

1.2.3 Case study of implementation in Austria: IST Austria 1.2.3.1 Organizational Structure

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• Situation before electronic signature – Paper printout of GA/GPFs were

• Printed/received from Coordinator by Grant Office • Checked by Grant Office • Initialed by Grant Office • Signed by President (on paper) • Scanned and sent by Grant Office to EC/ERCEA/Coordinator

• Electronic Signature now – Paper printout of GA/Declaration of honour is

• Printed by Grant Office • Checked by Grant Office • Initialed by Grant Office • Signed by President (on paper) • Signed via President‘s account online • Paper signatures are kept in Grant Office

• Differences


• Form C signature only signature on paper if CFS is needed (on the draft Form C version)

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1.2.3.4 Electronic signature processing in Austria

• Universities in Austria in H2020 – Set up internal rules and procedures

– PLSIGN usually the Rector responsible for Research

– FSIGN usually in Finance

– LEAR usually Head of Grant Office/Head of Grant Services

• FWF (Austrian Science Fund) for basic research – Just introduced an online application system

– Signatures still have to be sent in hard copy/qualified electronic signature

• other Austrian funding institutions – Scanned signatures in pdf are mostly ok, no electronic signature systems in

place

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1.3 The electronic signature in FP7 projects

1.3.1 The process of switching to electronic-only process 1.3.2 The documents concerned 1.3.3 Special clause 10 – Linked third parties

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1.3.1 The process of switching to electronic-only process for FP7 projects

Situation:

- For projects signed after January 1, 2013

- Electronic-only submission

- For projects signed before January 1, 2013

- Grants agreements are not automatically affected

- The consortium may opt for the application of the electronic-only signature and transmission

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Procedure: • EC sends and e-mail proposing a request for amendment to the grant agreement

concerned

• It is the decision of the beneficiary to accept or refuse the switch to electronic-only process

• In a consortium, the coordinator liaise with the beneficiaries to obtain their postion

• Coordinator signs the request for amendment

• EC sends the amendment both by e-mail and registered mail

• Beneficiary shall acknowledge receipt of the e-mail

• Beneficiary confirms by e-mail within 7 days of receipt of the said e-mail that :

– all necessary steps have been taken,

– the persons authorised to sign Form C for the organisations concerned are indentified in the Participant Portal

– All relevant access rights have been properly granted

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Conditions (Annex II. General conditions):

• Each beneficiary shall designate a legal entity appointed representative (LEAR) having due electronic access (extended mandate)

• In a consortium:

– The coordinator shall obtain the agreement of all beneficiaries to switch to electronic-only process

– The coordinator shall ensure that all beneficiaries have appointed a LEAR with extended mandate, a FSIGN and that all relevant access rights have been granted on the Participant Portal

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1.3.2 The documents concerned

- Form C (financial statement) - Certificate on the financial statements (Form D) - Certificate on the methodology (Form E)

Annex II. General conditions - Point 5 of Article II.4 is replaced by the following:

"The consortium shall transmit the reports and other deliverables through the coordinator to the Commission using the electronic exchange system set up by the Commission. In particular:

• Form C must be transmitted and electronically signed through the electronic exchange system by the authorised person(s) within the beneficiary's organisation.

• The certificates on the financial statements and on the methodology must be hand-signed by an authorised person of the auditing entity on paper and the beneficiary shall keep the originals according to Article II.22.3. A scanned copy of the certificates shall be transmitted through the electronic exchange system".

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1.3.3 Special clause 10 – Linked third parties

If there is a special clause 10 in the GA, linked third parties are also affected by the change

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Special clause 10 (linked third parties) prior to electronic submission

« This beneficiary may charge costs incurred by the above-mentioned third parties in carrying our the project, in accordance with the provisions of the grant agreement. These contributions shall not be considered as receipts of the project. The third parties shall identify the costs to the project mutatis mutandis in accordance with the provisions of Part B of Annex II of the grant agreement. Each third party shall charge its eligible costs in accordance with the principles established in Articles II.14 and II.15. The beneficiary shall provide to the Agency:

- An individual financial statement from each third party in the format specified in Annex IV. These costs shall not be included in the beneficiary’s Annex IV.

- Certificates on the financial statements and/or on the methodology from each third party in accordance with the relevant provisions of this grant agreement.

- A summary financial report consolidating the sum of the eligible costs borne by the third parties and the beneficiary, as stated in their individual financial statements, shall be appended to the beneficiary’s Annex IV.

When submitting the financial management reports referred to in Article II.4, the beneficiary(s) shall identify work performed and resources deployed by each third party linking it to the corresponding beneficiary. »

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Special clause 10 (linked third parties) modified (electronic-only submission)

« This beneficiary may charge costs incurred by the above-mentioned third parties in carrying our the project, in accordance with the provisions of the grant agreement. These contributions shall not be considered as receipts of the project.

The third parties shall identify the costs to the project mutatis mutandis in accordance with the provisions of Part B of Annex II of the grant agreement. Each third party shall charge its eligible costs in accordance with the principles established in Articles II.14 and II.15. The beneficiary shall transmit to the Agency using the electronic exchange system set up by the Commission:

a.An individual financial statement from each third party in the format specified in Annex IV. These costs shall not be included in the beneficiary’s Annex IV.

b.Certificates on the financial statements and/or on the methodology from each third party in accordance with the relevant provisions of this grant agreement.

The beneficiary shall keep the originals of the Annex IV and the certificates of the third parties according to Article II.22.3. »

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Form C of linked third parties

The submission of Form C is electronic-only

However, the beneficiary shall keep the originals of the Annex IV-Form C of the third parties

Form D and/or Form E of linked third parties

The beneficiary must have the Form D and/or Form E hand-signed by an authorised person of the auditing entity on paper

A scanned copy of the certificates shall be transmitted through the electronic exchange system

The beneficiary shall keep the originals of the Form D and/or Form E of the linked third parties

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2. Status/validity of the electronic signature in H2020 2.1 EU legislation

2.1.1 The legal framework

2.1.2 The 3 types of electronic signatures and the qualified certificate

2.1.3 The Financial Regulation

2.1.4 Rules of Application

2.1.5 EU Horizon 2020 Rules for Participation


2.2.1 Between the EC and the beneficiaries

2.2.2 Between the beneficiaries and third parties

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2.1 EU legislation

2.1.1 The legal framework

• establishes the legal framework at European level for electronic signatures and certification services

• aims to make electronic signatures easier to use and help them become legally recognised within the Member States

• lays down the criteria that form the basis for legal recognition of electronic signatures by focusing on certification services

• The Directive comprises:

• common obligations for certification service providers in order to secure transborder recognition of signatures and certificates throughout the European Community;

• common rules on liability to help build confidence among users, who rely on the certificates, and among service providers;

• cooperative mechanisms to facilitate transborder recognition of signatures and certificates with third countries.

Reminder: A Directive shall be transposed into the legislation of each Members states. Example: in France, Civil code, article 1316-4.

Directive 1999/93/EC of the European Parliament and of the Council of 13 December 1999 on a Community framework for electronic signature

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2.1.2 The 3 types of electronic signatures

The electronic signature

The advanced electronic signature

The qualified electronic signature

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The electronic signature

o Definition: data in electronic form which are attached to or logically associated with other electronic data and which serve as a method of authentication

o It can be as simple as signing an e-mail message with a personal name.

o To be a signature the authentication must relate to data and not be used as a method or technology only for entity authentication.

o For instance, when a person uses a PIN code to identify himself in order to get access to an electronic bank account, it is not an electronic signature.

o However, entering the same code in order to confirm a financial transaction and, in doing so authenticating this transaction, is an electronic signature. There are many applications making use of electronic signature technology, which do not qualify as electronic signatures according to the Directive when they are only used for entity authentication.

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The advanced electronic signature meets the following requirements:

1. It is uniquely linked to the signatory

2. It is capable of identifying the signatory

3. It is created using means that the signatory can maintain under their sole control

4. It is linked to the data to which it relates in such a manner that any subsequent change in the data is detectable

The Directive does not favour a particular technology but in practice, this definition refers mainly to electronic signatures based on a public key infrastructure (PKI). This technology uses encryption technology to sign data, which requires a public and a private key.

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The “qualified” electronic signature:

mentioned in Article 5.1 of the Directive

consists of an advanced electronic signature based on a qualified certificate and created by a secure signature creation device which needs to comply with the requirements in Annexes I, II and III

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The qualified certificate

Qualified certificates must contain (Annex I):

a) an indication that the certificate is issued as a qualified certificate; b) the identification of the certification-service-provider and the State in which it is

established; c) the name of the signatory or a pseudonym, which shall be identified as such; d) provision for a specific attribute of the signatory to be included if relevant,

depending on the purpose for which the certificate is intended; e) signature-verification data which correspond to signature-creation data under the

control of the signatory; f) an indication of the beginning and end of the period of validity of the certificate; g) the identity code of the certificate; h) the advanced electronic signature of the certification-service-provider issuing it; i) limitations on the scope of use of the certificate, if applicable; and j) limits on the value of transactions for which the certificate can be used, if

applicable.

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Secure signature-creation devices

Requirements for secure signature-creation devices (Annex III):

1. Secure signature-creation devices must, by appropriate technical and procedural means, ensure at the least that:

a) the signature-creation-data used for signature generation can practically occur only once, and that their secrecy is reasonably assured;

b) the signature-creation-data used for signature generation cannot, with reasonable assurance, be derived and the signature is protected against forgery using currently available technology;

c) the signature-creation-data used for signature generation can be reliably protected by the legitimate signatory against the use of others.

2. Secure signature-creation devices must not alter the data to be signed or prevent such data from being presented to the signatory prior to the signature process.

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Qualified electronic signature is (SUMMARY): • an advanced electronic signature • based on a qualified certificate • created by a secure-signature-creation device • satisfies the legal requirements of a signature in relation to data in electronic form in

the same manner as a handwritten signature satisfies those requirements in relation to paper-based data

• It is also admissible as evidence in legal proceedings In addition, an electronic signature may not legally be refused simply because: • it is in electronic form; • it is not based on a qualified certificate; • it is not based upon a qualified certificate issued by an accredited certification service

provider; • it is not created by a secure signature-creation device

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Liability Member States must ensure that a certification service provider which issues a qualified certificate is liable vis-à-vis any person who reasonably relies on the certificate for:

• the accuracy of all information in the qualified certificate; • compliance with all requirements of the Directive in issuing the qualified

certificate; • assurance that the holder identified in the qualified certificate held, at the

time of the issuance of the certificate, the signature-creation device corresponding to the signature verification device given or identified in the certificate;

• in cases where the certification service provider generates the signature-creation device and the signature-verification device, assurance that the two devices function together in a complementary manner.

The certification service provider must not be liable for damage arising from use of a qualified certificate that exceeds the limitations placed on it.

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2.1.3 Financial Regulation

Preamble (33) This Regulation should foster the objective of e-Government, and in particular the use of

electronic data in the exchange of information between the institutions and third parties. (49) Progress towards electronic exchange of information and electronic submission of

documents, which constitute a major simplification measure, should be accompanied by clear conditions for the acceptance of the systems to be used, so as to establish a legally sound environment.

CHAPTER 7 IT systems and e-Government Article 93 Electronic management of operations 1. Where revenue and expenditure operations are managed by means of computer systems,

documents may be signed by a computerised or electronic procedure.

Regulation (EU, EURATOM) No 966/2012 of the European Parliament and of the Council of 25 October 2012 on the financial rules applicable to the general budget of the Union and repealing Council Regulation (EC, Euratom) No 1605/2002

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2.1.4 Rules of Application

CHAPTER 7 IT systems Article 112 Description of IT systems (Article 93 of the Financial Regulation) Where computer systems and subsystems are used to process budget implementation operations, a full and up-to-date description of each system or subsystem shall be required. Each description shall define the content of all data fields and describe how the system treats each individual operation. It shall show in detail how the system guarantees the existence of a complete audit trail for each operation. Article 113 Periodical save (Article 93 of the Financial Regulation) The data in computer systems and subsystems shall be saved periodically and kept in a safe place.

Commission Delegated Regulation (EU) No 1268/2012 of 29 October 2012 on the rules of application of Regulation (EU, Euratom) No 966/2012 of the European Parliament and of the Council on the financial rules applicable to the general budget of the Union

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Article 18 Secure electronic system The Commission or the relevant funding body may establish a secure electronic system for exchanges with the participants. A document submitted by means of this system, including grant agreements, shall be deemed to be the original of that document where the user identification and password of the participant's representative have been used. Such identification shall constitute the signature of the document concerned.

2.1.5 EU Horizon 2020 Rules for Participation

Regulation (EU) No 1290/2013 of the European Parliament and of the Council of 11 December 2013 laying down the rules for participation and dissemination in "Horizon 2020 - the Framework Programme for Research and Innovation (2014-2020)“ and repealing Regulation (EC) No 1906/2006

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2.2.1 Between the EC and the beneficiaries The process of electronic signature in H2020 is not a qualified electronic signature

It is an advanced electronic signature No ink & paper version required

Status regarding Associated countries and Third Countries that are Beneficiaries to

the GA: Directive: Members states must ensure that mutual legal recognition of

qualified certificates and electronic signatures from third countries is applied if certain reliability conditions are met. The Commission may make proposals to ensure that international standards and agreements are fully implemented.

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Associated countries

Bilateral agreements signed between the EU and Associated Countries

(Article 7 of the Horizon 2020 Regulation Mutual recognition

By 17 December 2014, Association Agreements have been concluded and/or signed with the following countries:

Apply retroactively from 1 January 2014 except for the Agreement with Switzerland, which is retroactively applicable as of 15 September 2014

Ukraine: coming soon

Iceland - Norway – Albania - Bosnia and Herzegovina the former Yugoslav Republic of Macedonia

Montenegro - Serbia Turkey – Israel - Moldova - Switzerland - Faroe Islands

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Third countries

Mutual recognition

Afghanistan, Albania, Algeria, American Samoa, Angola, Argentina, Armenia, Azerbaijan,

Bangladesh, Belarus, Belize, Benin, Bhutan, Bolivia, Bosnia and Herzegovina, Botswana, Burkina

Faso, Burundi, Cambodia, Cameroon, Cape Verde, Central African Republic, Chad, Chile, Colombia,

Comoros, Congo (Democratic People’s Republic), Congo (Republic), Costa Rica, Côte d’Ivoire,

Cuba, Djibouti, Dominica, Dominican Republic, Ecuador, Egypt, El Salvador, Eritrea, Ethiopia, Fiji,

Gabon, Gambia, Georgia, Ghana, Grenada, Guatemala, Guinea, Guinea-Buissau, Guyana, Haiti,

Honduras, Indonesia, Iran, Iraq, Jamaica, Jordan, Kazakhstan, Kenya, Kiribati, Korea (Democratic

Republic), Kosovo*, Kyrgyz Republic, Lao, Lebanon, Lesotho, Liberia, Libya, former Yugoslav

Republic of Macedonia, Madagascar, Malawi, Malaysia, Maldives, Mali, Marshall Islands, Mauritania,

Mauritius, Micronesia, Moldova, Mongolia, Montenegro, Morocco, Mozambique, Myanmar, Namibia,

Nepal, Nicaragua, Niger, Nigeria, Pakistan, Palau, Palestine, Panama, Papua New Guinea,

Paraguay, Peru, Philippines, Rwanda, Samoa, Sao Tome and Principe, Senegal, Serbia, Seychelles,

Sierra Leone, Solomon Islands, Somalia, South Africa, South Sudan, Sri Lanka, St. Kitts and Nevis,

St. Lucia, St. Vincent and the Grenadines, Sudan, Suriname, Swaziland, Syrian Arab Republic,

Tajikistan, Tanzania, Thailand, Timor-Leste, Togo, Tonga, Tunisia, Turkey, Turkmenistan, Tuvalu,

Uganda, Ukraine, Uzbekistan, Vanuatu, Uruguay, Venezuela, Vietnam, , Yemen, Zambia, Zimbabwe.

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2.2.2 Between the beneficiaries and third parties Directive: Members states must ensure that mutual legal recognition of qualified

certificates and electronic signatures from third countries is applied if certain reliability conditions are met. The Commission may make proposals to ensure that international standards and agreements are fully implemented.

Status regarding third parties to the GA

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Thank you for your attention!

Ludivine BONADEI

Carla MAZUHELI-CHIBIDZIURA

Chelo MORAN SAGREDO