Digitally signing electronic documents: process and legal validity under Decree 23/2025

A decision is already approved in the system, yet it still gets printed so it can be stamped and signed by hand, then scanned back in for filing. Many offices know that loop well. The blunt question behind any discussion of digitally signing electronic documents is the same: can the paper copy go away, and if it does, is the document still legally valid?

Yes, under two conditions. The document must carry the digital signature of the authorized person and the digital signature of the organization itself — with both, it has the same legal value as the paper original. And the electronic records system must meet the technical requirements that allow the electronic original to be kept in place of paper. Without the second, the office still has to print and file.

The legal frame after 10 April 2025

On 10 April 2025, Decree 23/2025/ND-CP on electronic signatures and trust services took effect. It was issued on 21 February 2025 and repeals Decree 130/2018/ND-CP and Decree 48/2024/ND-CP. Internal regulations or tender files still citing the older decrees need a review.

Three layers of rules are worth separating right away, because confusing them leads to the wrong implementation.

• Law on Electronic Transactions 20/2023/QH15. Article 22 clause 1 sorts electronic signatures by scope into three kinds: dedicated, public digital, and dedicated public-duty. Article 23 clause 2 gives a secured dedicated electronic signature, or a digital signature, the same legal value as a handwritten one.
• Decree 23/2025/ND-CP. Details certificates, trust services and technical conditions. Article 1 states it does not cover dedicated public-duty digital signatures, which fall under Decree 68/2024/ND-CP and the Government Cipher Committee.
• Decree 30/2020/ND-CP on clerical work. This is the text that says who signs what, where the signature sits, and how issuance and filing work. Most practical friction lives here rather than in Decree 23/2025.

Decree 23/2025 also imposes mandatory functional requirements on signing software, with an upgrade deadline for systems in production; that technical side is covered in our piece on what Article 17 requires of signing software. This article stays operational.

Two signatures on one document, not one

This is the detail most often missed when administrative documents move to digital signing for the first time.

Article 8 of Decree 30/2020/ND-CP lists the required components of an administrative document, two of which are distinct: the title, full name and signature of the authorized person; and the seal or digital signature of the organization. On paper that is the head of office signing by hand plus the red seal. In electronic form it is two different digital signatures belonging to two different subjects.

Article 5 is explicit: an electronic document signed by the authorized person and by the organization has the same legal value as the paper original. Without the organization's signature the document is incomplete in form, even if the leader has signed.

The organization's digital signature is the electronic seal. It is bound to a certificate issued to the legal entity rather than to an individual, and it lives on its own secret-key storage device. Article 32 assigns that device to the clerical unit, kept at the office premises, and allows the organization signature only on a document that already carries the authorized person's signature. The order is mandatory: the leader signs first, the clerical unit second. A system that lets the electronic seal go on first is breaking the clerical process, however cryptographically valid that signature may be.

Placement and rendering are not a free choice either; Article 13 clause 7 refers to Appendix I. A small detail, easily skipped when integrating a signing library directly, and the reason many signed documents do not look like standard ones.

The signing process inside an organization

Article 14 sets out five steps for outgoing documents: assign the number and issuance time, register, apply the organization's digital signature, issue and track delivery, and file. Placed next to the drafting and approval provisions in Chapter II, the full flow looks like this.

• Drafting. The assigned drafter puts the draft and attachments into the system. Comments are recorded there rather than on a printout.
• Approval and form check. The person with signing authority approves the draft. In parallel, a separate person is responsible for form and presentation. Two distinct responsibilities, so keep them as two workflow steps.
• Signature of the authorized person. This creates the original: under Article 3, the original is the document complete in content and form, digitally signed by the authorized person.
• Numbering and registration. The number and issuance time are assigned by a system function. Number and symbol are unique within the year and consistent across paper and electronic documents — two separate number pools is a common design mistake.
• Organization signature. Applied by the clerical unit, replacing physical stamping.
• Issuance and filing. Issue on the day of signing, at the latest the next working day; urgent documents go out immediately. The electronic original stays in the issuing organization's system.

Multi-level routing and signing authority

Multi-level signing is not really a technical problem; it is the job of mapping actual signing authority into software. Article 13 covers the situations every office regulation contains: the head signs; a deputy signs on their behalf within an assigned area; someone signs for a collective leadership; someone signs by delegation in special cases, in writing, limited in time and subject matter, with no sub-delegation; and someone signs by order under the working regulation. A few things are worth settling before building the flow.

• Who may sign which document type. The authority matrix belongs in system configuration, not in the clerical officer's memory. Signing outside your authority still produces a cryptographically valid signature and a legally defective document.
• Time-bounded delegation. Delegation in the system needs a start date, an end date and a document-type scope, expiring on its own rather than waiting for someone to remember.
• A complete trail. Every approval, signature and rejection needs a log entry with timestamp, subject and outcome. That trail is the only thing that answers "who agreed to this" two years later.
• No signing by lending the token. Handing the secret-key device to someone else destroys the point of a digital signature. For the organization's device, any handover requires written permission and a handover record.

Handling inbound documents that arrive signed

The receiving side usually gets less attention than the sending side, though much of the risk sits there. Article 21 clause 2 requires the clerical unit to check the authenticity and integrity of an incoming electronic document before accepting it into the system. If it fails, or went to the wrong recipient, it must be returned to the sender through the system; once accepted, the sender must be notified the same day.

Checking here means more than "does it have a signature". Under Article 3 of Decree 23/2025, a valid certificate is one that has not expired, is not suspended and has not been revoked. Three states, not one. A system that only compares expiry dates will happily accept a document signed with a revoked certificate.

Where the signing time itself needs proving, the timestamp must come from a licensed trust service provider. Article 32 of Decree 23/2025 places responsibility on the recipient who accepts a timestamp that fails those conditions, or who accepts one while already aware the related certificate was revoked, suspended or expired. The list of licensed providers and certificate statuses is published by the National Electronic Authentication Centre.

Archiving signed documents and verifying them years later

This is the part that decides whether paper really goes away.

Article 19 splits into two cases. An organization whose system meets Appendix VI of Decree 30/2020 may store the electronic original in place of paper. One whose system does not must still have the clerical unit produce a paper original for the clerical and working files. The ability to drop paper therefore depends directly on system compliance — a question worth asking during software selection, not after.

Once closed, electronic files go to the organization's archive through the system, indexed by a system function, within one year of the work completing (three months from final settlement for capital-construction files). Archives Law 33/2024/QH15, issued 21 June 2024, takes effect on 1 July 2025, so internal archiving rules deserve a review this year.

The hard problem in electronic archiving is time. Under Article 7 of Decree 23/2025, a public digital-signature certificate is valid for at most three years; a dedicated electronic-signature certificate, where the signature is backed by a dedicated certificate, for ten. Many files are kept permanently. An expired certificate does not invalidate a signature already made, but proving it was valid at signing time gets harder over the years.

So at issuance, store alongside the document: the full certificate chain, evidence of certificate status at the moment of signing, and a timestamp. Adding those years later is effectively impossible. The archive should also sit in-country and under the organization's control, since this data is kept for a very long time — a theme covered in our piece on storing data domestically.

Converting between paper and electronic

Both directions are regulated, and both use the organization's digital signature.

• Electronic to paper. Article 18 clause 5 lets the clerical unit print a document already signed by the authorized person, apply the organization's seal to create a paper original, and issue it — for recipients not yet able to receive electronic documents.
• Paper to electronic. Article 25 clause 1(c) provides that a certified copy from paper to electronic form is made by digitizing the paper document and applying the organization's digital signature. Done correctly it has the same legal value as the original under Article 26. A scan without that signature is just an image.
• Recalling a document. The recipient deletes the recalled document in the system and notifies the sender through it. That function needs to exist rather than being handled by email.

The same logic is spreading into financial records, most recently with Decree 70/2025 on electronic invoices.

A review checklist

None of this costs budget, and all of it can start now:

• Compare the documents you currently issue against Article 8: do they carry both the authorized person's signature and the organization's, and does placement follow Appendix I.
• Check signing order: can the system stop the organization signature from being applied before the leader has signed.
• Review the signing-authority matrix and every active delegation against the real configuration in the software.
• Test the receiving side: feed in a document signed with a revoked certificate and see whether it is caught.
• Determine whether your system meets Appendix VI of Decree 30/2020; if not, list the gaps and estimate the cost.
• Open a document signed a year ago: can you still verify it, and were the certificate chain and timestamp stored with it.
• Review expiry dates of every certificate in use and set renewal reminders at least a month ahead.

Decree 30/2020 applies to state agencies, state organizations and state-owned enterprises. Private companies are not bound by it, but most are better off using it as the reference standard for internal clerical rules, since any interaction with a state agency has to fit its flow anyway.

Tetra eOffice is built around that flow: a signing-authority matrix, the authorized person's signature kept separate from the organization's, signature verification on inbound documents, complete audit logs, and electronic originals stored on your own infrastructure.

Conclusion

Decree 23/2025 standardizes signatures and trust services, but whether an office can actually drop paper is still decided by Decree 30/2020: both signatures, in the right order, from the right authority, on a system compliant enough to hold the electronic original.

Start by comparing a freshly issued document against the required form, then try to verify one signed last year. Those two tests tell you fairly precisely where you stand.

If you need a review of your current routing process or want to discuss deployment on your own infrastructure, book a consultation with the Tetra team.

Note: this article is for reference only. When implementing, check directly against the current legal texts and guidance from the competent authority.