Introduction
The physical letter signed, sent, received, and archived remains a deeply rooted element of European administrative and business culture. Yet the growing need for efficiency, security, and cross-border interoperability has accelerated the shift toward digital correspondence. This article examines how the European Union and its member states have addressed this transition, focusing on the eIDAS Regulation, which established a legal framework for trust services, and Germany’s De-Mail system, an early national experiment. Together, they demonstrate how the traditional actions of “send,” “deliver,” and “archive” have been redefined through verifiable digital proof identity checks, time stamps, tamper-evident seals, and receipts. Replacing paper is not merely about digitization but about creating a secure, registered digital letter equivalent that upholds trust, traceability, and accountability in modern communication.
The Legal Foundation: eIDAS and trust services
In July 2014, the European Parliament and Council adopted Regulation (EU) No 910/2014 on electronic identification and trust services for electronic transactions in the internal market, known as eIDAS. This regulation established, in official letter-style framing, that electronic identification, electronic signatures, electronic seals, electronic time stamps, and certified electronic delivery services shall be recognized across Member States.
Under eIDAS:
- Action: Verify signatory identity via a qualified electronic signature or seal. Proof: the signature uses a certificate issued by a qualified trust service provider (QTSP).
- Action: Time-stamp the digital document. Proof: the time-stamp is issued by a trust service and links the record to the moment of sealing.
- Action: Provide delivery assurance (registered electronic delivery). Proof: the service records sender, recipient, timestamp, and maintains an audit trail; courts shall not deny legal effect to an electronic document solely on the grounds of being electronic.
- Action: Archive records with integrity and traceability. Proof: trust service providers must maintain audit trails, and their services are subject to conformity assessment.
A digital letter equivalent under the eIDAS framework must be sendable, received, verified, time-stamped, sealed, auditable, and archiveable just like a paper letter, but with more robust proof of every step.
Germany’s De-Mail: A national experiment
One of the most prominent country-level efforts to replace paper correspondence with a secure digital letter service is Germany’s De-Mail. Introduced via the German federal government in cooperation with private providers, De-Mail sought to provide “secure electronic correspondence … simple and verifiable.”
Key features:
- Send and receive digital letters with encryption and authentication. Each recipient must be unambiguously identified, messages are encrypted, and a registered service records each transaction.
- Deliver correspondence that is “as binding as a letter”. The De-Mail law (coming into effect in 2011) created legal status for the service.
- Provide audit trail and proof of delivery. Sender receives confirmation of delivery to the identified recipient; service records the sending and receiving events.
However, the real-world outcomes were mixed. According to the German federal auditor, although in 2014 the aim was to send up to 6 million De-Mails in four years from public authorities, the actual number was only about 6,000, resulting in small cost savings rather than the projected multi-million euro benefit.
De-Mail shows the importance of linking the digital service to clear demand, workflow redesign, and incentive alignment. Merely replacing paper with a digital service is not sufficient unless the senders and recipients embrace the paradigm shift and the proof mechanisms (recipient identity, time-stamp, audit trail) are fully trusted and used.
Broader EU dynamics and cultural attachment to paper
Despite legal frameworks and national services, the “love of paper” persists in many member states for official correspondence, contractual letters, and archived documents. Several factors help explain the inertia:
- Paper conveys tangibility, familiarity, and perception of legal solidity. Transitioning to digital requires building trust in identity verification, encryption, time-stamping, and archive integrity.
- Operational workflows and legacy systems remain tied to paper. Changing that means organizations must redesign processes to send digitally, verify recipient identities, seal records, deliver via secure link, acknowledge receipt, and archive with proof. The work is organizational and cultural, not just technical.
- Legal and regulatory requirements vary across sectors and jurisdictions; some still require wet-ink signatures or paper letters by default, even if digital alternatives exist.
- Digital-inclusion and access issues: Some correspondents (public, private) may prefer paper for reasons of habit, technology access, or perceived reliability. The shift demands leadership from senior management and policymakers setting mandates, incentives or requirements.
The EU’s broader e-government agenda recognizes this shift. The European Commission emphasizes that digital public services enable citizens, enterprises, and organizations to carry out their interactions more easily, more quickly, and at lower cost.
Digital Strategy Initiatives, such as the “e-Cohesion” regulations, drive electronic data exchange in public funds and administration, reducing reliance on paper-based submissions.
eIDAS 2.O
eIDAS 2.0, plainly explained. In April 2024, the EU adopted Regulation (EU) 2024/1183, which amends the 2014 eIDAS framework and establishes a European Digital Identity regime. It was published on 30 April 2024 and entered into force 20 days later, creating the legal basis for EU‑wide, verifiable digital identity and trust services.
eIDAS 1.0 created the single market for electronic identification and trust services, such as qualified electronic signatures and seals, electronic registered delivery, timestamps, and website authentication; plus cross‑border recognition of notified national eID schemes. eIDAS 2.0 added and expanded qualified trust services, Qualified Electronic Attestation of Attributes (QEAA), Qualified Electronic Archiving (integrity presumption for preserved data); Qualified Electronic Ledgers (presumption of chronological ordering and integrity); and Qualified Management of Remote Signature/Seal Devices (remote QSCD). These are recognized across Member States.
The approval of eIDAS 2.0 indicates that the EU is confident in the digitalization of paper-based workflows; considering De-Mail failure lessons, they are supporting the change via setting supporting regulations.
Lessons learned and strategic implications
Reflecting on past endeavours yields several actionable insights:
- Design for proof: A digital service must deliver verifiable proof of recipient identity verification, a time-stamped receipt, a tamper-evident record, archive trace. Without these, the “letter” loses the legal and organizational integrity of its paper predecessor.
- Ensure interoperability and standards alignment: The eIDAS framework underscores that trust services should be compliant, and national schemes must interoperate across borders. Digital letters need to work not only within a country but across jurisdictions when relevant.
- Align incentives and workflows: Germany’s De-Mail case shows that even with a technically compliant service, low uptake can occur if organizational processes, user behaviour, and incentives are not aligned. Encourage senders and recipients to shift to the digital alternative and build acceptance of its proof mechanisms.
- Manage cultural and organizational change: The attachment to paper is not just technical; it is behavioural. Senior leadership must treat the transition as a correspondence redesign, not just a system installation.
- Recognize phased transition: It may be unrealistic to eliminate paper overnight. Hybrid models where digital letters are the default but paper remains optionally available may ease the shift. Encourage digital as the standard, but retain fallback channels where necessary.
- Match legal/regulatory context: Confirm that your digital letter service conforms with applicable national and EU law, and that the trusted service provider is recognized. Safe claim reminder: legally recognized delivery options available in many regions; confirm local requirements.
- Monitor outcomes and proof metrics: Track uptake, proof-package delivery (recipient identity + time-stamp + receipt confirmation + audit trail), cost savings, error rates, and stakeholder satisfaction.
Conclusion
The journey from paper letters to secure digital letters that carry the same weight, verified delivery, identity assurance, time-stamped record, and audit trail has been underway in the European Union for some years. The eIDAS regulation created the legal foundation for trust services, and national initiatives such as Germany’s De-Mail provided operational experiments. For policymakers and CEOs today, the key is not simply to digitize correspondence, but to adopt a fully-formed digital letter service: one that sends, verifies, delivers, seals, archives, and trails with proof at each step. The culture of paper may persist, but organizations that adopt the mindset of digital letters backed by proof will be better placed for efficiency, compliance, cross-border operation, and resilience.
Letro is a secure end to end encrypted #FormalCommunication platform designed for mobile and computer. To get more information Request a demo.
