The Regulation of the Council of Ministers of 9 March 2020 on Documents Connected with Banking Activities on IT Data Carriers enters into force on 19 September 2020. This is a good occasion to discuss the expanded legal significance of the electronic seal.
The new regulation supersedes the prior executive regulation under Art. 7 of the Polish Banking Law. The noteworthy features of the new regulation include the systemic consolidation of the terminology through introduction of concepts consistent with the EU’s eIDAS Regulation (910/2014) and a direct reference to distributed ledger technology. (I will address the treatment of this technology in a separate article.)
It appears that inclusion in the new Polish regulation of terminology consistent with the eIDAS Regulation is more than a mere technicality. A closer analysis of the provisions raises the question of whether the regulation in fact expands the legal significance of the electronic seal.
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