Brazil — Law 14.063/2020 (simple/advanced/qualified tiers)

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Law No. 14.063 of 09232020. Creates 3 tiers of electronic signature for interactions between individuals and public entities. Coexists with MP 2.200-2 (does not repeal it).

The 3 tiers (Art. 4)

Tier Legal definition Typical technology Where it applies
Simple Allows identifying the signatory; attaches or associates data with other data Password + email; OAuth; SMS code; clicking "I agree" Low-risk documents; routine communication with public administration
Advanced Technology that: (i) is uniquely associated with the signatory; (ii) uses data under the signatory's exclusive control; (iii) detects any subsequent modification Digital certificate outside ICP-Brasil; strong biometrics; gov.br gold/silver tier in certain cases Medium-risk documents; asset records; tax matters with public administration (except where the Law requires qualified)
Qualified Uses an ICP-Brasil digital certificate, as set out in the regulation ICP-Brasil A1A3A4; e-CPF/e-CNPJ Mandatory for: issuance of NF-e; documents involving onerous real-estate transfer ≥ R$ 30k; acts before the Electoral Justice; other cases under Art. 5

Practical difference vs MP 2.200-2

  • MP 2.200-2 defines the infrastructure (ICP-Brasil) and the presumption of authenticity of the ICP signature. Focused on cryptographic digital signature.
  • Law 14.063 classifies any electronic signature into tiers for the government↔citizen context. Includes the "click to agree" as the simple tier.

Where each tier is accepted (Art. 5)

  • Simple — any interaction that does not require a higher tier. Logging into e-CAC with password + SMS code, for example.
  • Advanced — when the law does not explicitly require the qualified tier. Includes signing via gov.br silver/gold tier (in-person or biometric validation) in various acts.
  • Qualified — required for:
    • Acts of transfer and registration of real estate ≥ R$ 30k (Art. 5 §1 III)
    • Health-related documents issued by professionals (Art. 6 §1)
    • Electronic tax invoices (related tax legislation)
    • Other cases where the public entity requires it

gov.br as advanced signature

The Law is technologically neutral, but the federal government regulated via Decree 10.543/2020 + subsequent ordinances that gov.br silver and gold tiers are equivalent to an advanced signature for acts where the qualified tier is not mandatory.

  • gov.br bronze — basic identification only, ≈ simple
  • gov.br silver — TSE biometrics OR bank validation OR digital certificate → advanced
  • gov.br gold — facial biometrics from CNH/TRE → advanced

URL to sign: assinador.iti.br — gov.br advanced signature, free of charge.

Implications for Koder Sign

Direct mapping:

Law 14.063 tier Likely Koder Sign implementation
Simple Koder ID OAuth + click → product ships it as MVP
Advanced Own digital certificate (non-ICP) issued by services/foundation/certs "user-signing" branch + biometrics via Koder ID or gov.br partnership
Qualified Only as an ICP-Brasil client (A1/A3) — do not build our own

Text compared with eIDAS

Law 14.063 consciously mirrored the structure of eIDAS (EU RFC 910/2014). Equivalences:

14.063 (BR) eIDAS (EU)
Simple SES — Simple Electronic Signature
Advanced AdES — Advanced Electronic Signature
Qualified QES — Qualified Electronic Signature

Formal cross-recognition Brazil↔EU does not exist — an eIDAS QES signature is not automatically qualified in Brazil and vice versa. Bilateral negotiations are on the MERCOSUR-EU agenda but with no timeline.

References