Misuse of Electronic Signatures and eID Owner Liability: A Comparative Analysis of Estonian and Norwegian Legislative Frameworks and Practice - European Business Law Review View Misuse of Electronic Signatures and eID Owner Liability: A Comparative Analysis of Estonian and Norwegian Legislative Frameworks and Practice by - European Business Law Review Misuse of Electronic Signatures and eID Owner Liability: A Comparative Analysis of Estonian and Norwegian Legislative Frameworks and Practice 36 2

The issuance of electronic identity (eID) will become compulsory across the EU according to Regulation (EU) 2024/1183 which amends Regulation (EU) 910/2014 as regards establishing the European Digital Identity Framework. Estonia and Norway both have extensive experience in the use of eID. Ample Norwegian and Estonian civil and criminal case law exists analysing the eID owner’s liability in cases of misuse of eID by a third person. Civil courts tend to take a different approach than criminal courts. In civil proceedings, the eID owner is often found liable, whether in contract or tort, in cases of misuse of eID by a third person. In criminal proceedings, courts tend to find the misuser of eID guilty (in cases of computer-related fraud) and ground the eID misuser’s liability in tort. This creates a situation where the creditor can choose against whom to bring their claim (depending e.g. on the financial status of the eID owner and the misuser) in order to ensure that their interests are well protected. However, the eID owner’s obligation to repay money to the creditor may depend on the type of proceedings chosen by the creditor. Focusing on situations where a third party has misused an owner’s eID, the authors analyse Estonian and Norwegian legislation and case law in order to determine who should be held liable under civil law.

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