ABSTRACT
This chapter compares different approaches adopted in the international, EU, US and Chinese legislation and their current legislative development, by looking into the definitions, features, benefits and functions of electronic signatures and electronic authentication. It considers the various forms, conditions and requirements of establishing Trusted Third Parties, called certificate authorities (CAs), which provide electronic signatures and authentication services at the national and international level. In contrast to electronic authentication, electronic signatures focus particularly on verifying the identity of the owners and deal with the problem of documental attribution, while electronic authentication deals with the problem of the reliability of key encryption and its key holders. To facilitate international harmonisation, in particular of the legal recognition of foreign certificates and electronic signatures, Working Group of the United Nations Commission on International Trade Law (UNCITRAL) requested the Secretariat to continue looking into these issues.
