Are e-signatures valid with clients abroad? EU, UK, Canada, Mexico and Brazil
By SoloWOS teamPublished Updated
IN SHORT
Simple electronic signatures are generally valid for business services contracts in the EU (eIDAS), the UK, Canada, Mexico and Brazil. Each country excludes some documents, such as wills, property transfers or deeds that need a witness, and some filings require an advanced or qualified signature. For a freelance services contract, an e-signature with an audit trail is the usual choice.
Prices and limits as of .
Key takeaways
- EU: eIDAS article 25 says an electronic signature can't be denied legal effect just because it's electronic; only a qualified signature automatically equals a handwritten one.
- UK: the Law Commission concluded in 2019 that an electronic signature can execute a document, including a deed, though deeds still need a witness physically present.
- Canada: provincial electronic commerce acts (Ontario's from 2000, for example) accept e-signatures and exclude wills and some powers of attorney.
- Mexico and Brazil both accept simple e-signatures between private parties and define an advanced level for when the law or the parties require it.
This page is general information, not legal advice, and it hasn't been reviewed by a lawyer in each country. Laws change and differ by document type. For a large contract, ask a lawyer licensed in the client's country.
US rules are covered in are electronic signatures legal?. This page adds the five places US freelancers most often sign with, and it's part of our contracts and signatures guides. Signature levels (simple, advanced, qualified) are explained in electronic vs digital signature.
Country table
| Country | Main law | Levels | Usually excluded or stricter | For a freelance services contract |
|---|---|---|---|---|
| European Union | Regulation (EU) 910/2014 (eIDAS), arts. 25-26 | Simple, advanced, qualified | Set by each member state's national law (property, family law, some notarial acts) | Simple e-signature with audit trail; qualified only if the client or a national rule requires it |
| United Kingdom | Electronic Communications Act 2000, s. 7; Law Commission report 2019 | Any electronic signature adopted to authenticate; witnessing rules for deeds | Deeds need a witness physically present; HM Land Registry sets its own rules for e-signed deeds | Simple e-signature; for a deed, follow the witnessing rules |
| Canada | Provincial acts, e.g. Ontario Electronic Commerce Act, 2000; PIPEDA Part 2 for federal requirements | "Secure electronic signature" for some federal documents | Wills and codicils, trusts created by wills, powers of attorney for financial affairs or personal care (Ontario s. 31) | Simple e-signature; check the province named in the governing-law clause |
| Mexico | Código de Comercio, arts. 89-114 | Firma electrónica (simple) and firma electrónica avanzada o fiable (art. 97) | Acts the law requires before a notary (fedatario público) follow their own rules | Simple e-signature between businesses; keep the record intact (art. 93) |
| Brazil | MP 2.200-2/2001, art. 10; Lei 14.063/2020 | Simple, advanced, qualified (ICP-Brasil certificate) | Public bodies, regulators and registries may require an advanced or qualified signature | Non-ICP-Brasil e-signature is valid when the parties accept it (art. 10 § 2): say so in the contract |
European Union
Under eIDAS article 25, a court can't refuse an electronic signature as evidence or deny it legal effect solely because it is electronic or isn't qualified. A qualified electronic signature has the effect of a handwritten one and must be recognized in every member state. Which documents need more than a simple signature is up to national law, so a services contract with a client in Spain or Germany is fine with a simple e-signature, while a property deed is not. Rule of thumb: if no notary would be involved on paper, a simple e-signature usually does the job.
United Kingdom
Section 7 of the Electronic Communications Act 2000 makes electronic signatures admissible in evidence in legal proceedings. In its 2019 report (Law Com No 386), the Law Commission concluded that an electronic signature can validly execute a document, deeds included, when the signer intends to authenticate it and any formalities are met. The catch is deeds: the witness must be physically present, even if both use electronic signatures. Rule of thumb: an ordinary services contract is fine; anything labelled "deed" needs a witness.
Canada
Provinces have their own electronic commerce acts. Ontario's Act (S.O. 2000, c. 17) lets electronic signatures satisfy a signature requirement, and section 31 excludes wills and codicils, trusts created by wills, and powers of attorney for an individual's financial affairs or personal care. At federal level, PIPEDA Part 2 (s. 31) defines a "secure electronic signature" as one made with a technology prescribed by regulation, used for some documents federal law requires. Rule of thumb: name the province in the governing-law clause and check its act for the document type.
Mexico
In commercial matters, the Código de Comercio applies functional equivalence: where the law requires writing, a data message works if it stays intact and accessible (art. 93), and where it requires a signature, an electronic signature appropriate to the purpose works (art. 97). Article 97 also defines the firma electrónica avanzada o fiable: creation data that correspond only to the signer and are under their exclusive control, with any later change to the signature or the message detectable. Rule of thumb: a simple e-signature works for a B2B services contract. If the client is a Mexican company, it may also ask for a CFDI (electronic invoice), which is a separate tax matter.
Brazil
MP 2.200-2/2001 created the ICP-Brasil certificate system, and its article 10 § 2 says that other means of proving authorship and integrity are valid when the parties accept them or the person against whom the document is used accepts it. Lei 14.063/2020 (art. 4) sorts electronic signatures into simple, advanced and qualified (ICP-Brasil certificate); public bodies and regulators may ask for a specific level. Rule of thumb: add one sentence to the contract in which both parties accept electronic signatures through the platform you use.
Checklist before you send a contract abroad
- Name the governing law and courts in the contract. Without it, you may be arguing about which country's rules apply.
- Add a clause in which both parties agree to sign electronically and accept electronic copies as originals.
- Check the document type against the excluded list for the client's country: deeds, property, powers of attorney, anything that needs a notary.
- Ask the client whether their internal policy requires an advanced or qualified signature. Large EU companies sometimes do.
- Use the signer's own work email, and make sure the person signing has authority to bind the company.
- Keep the signed PDF with its audit trail and file fingerprint.
In SoloWOS
SoloWOS E-Signatures gives you simple electronic signatures with an audit trail: each signer consents, then signs from an email link on any device, and the certificate of completion records time, IP, device and SHA-256 fingerprints. The certificate is produced in your workspace's language. SoloWOS doesn't provide advanced or qualified signatures or notarization, so it isn't the right tool when a country requires those. Send PDFs for e-signature on Solo with 15 requests a month for $15/month. See also what an audit trail contains.
Questions
Can I e-sign a contract with a client in Germany or France?
For an ordinary services contract, generally yes. eIDAS says an electronic signature can't be denied legal effect just because it's electronic. National law decides which documents need a qualified or handwritten signature, so check if the document is anything beyond a business contract.
Which country's e-signature law applies to my contract?
Usually the law the contract names in its governing-law clause, plus any mandatory rules of the place where a document must be used or filed. If the contract is silent, the answer gets harder, which is why the clause is worth one line.
Do I need a qualified electronic signature for an EU client?
Rarely for a freelance services contract. Some companies require one by internal policy and some national rules require one for specific documents. Ask the client before you send.
Is a contract signed electronically valid in Mexico?
Between businesses, generally yes: the Código de Comercio recognizes electronic signatures and data messages as equivalent to paper when the content stays intact and accessible. Acts that must go before a notary are different.
Sources
Facts checked against these sources on October 23, 2026. Rules and amounts change, so confirm them at the source before you file or sign.
- Regulation (EU) No 910/2014 (eIDAS), consolidated text: arts. 3, 25 and 26
- UK Electronic Communications Act 2000, section 7
- Law Commission (England and Wales), Electronic Execution of Documents, Law Com No 386 (September 2019)
- Ontario Electronic Commerce Act, 2000, S.O. 2000, c. 17 (s. 31 exclusions)
- PIPEDA, Part 2: Electronic Documents (Justice Laws Website)
- Código de Comercio (México), arts. 89 a 114, Cámara de Diputados
- Medida Provisória nº 2.200-2/2001 (Brasil), art. 10
- Lei nº 14.063/2020 (Brasil), art. 4 (simple, advanced and qualified signatures)
Last reviewed:
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