China Introduces Nationwide Rules for Electronic Seals - What Enterprises Need to Know

The newly issued Administrative Measures for Electronic Seals (State Council General Office Document [2025] No. 33, effective 27 September 2025) establish a unified national framework for the creation, filing, use, and legal effect of electronic seals (e-seals). The rules took effect immediately upon publication and apply to all administrative organs, enterprises, institutions, and social organisations.

An electronic seal (e-seal) is cryptographically generated data that represents a physical seal in digital form and enables legally reliable electronic signatures on electronic documents. It contains the seal image, name, owner information, and a legally valid electronic signature certificate. Documents signed with compliant e-seals now enjoy the same legal effect as paper documents stamped with traditional seals.

The Measures explicitly promote cross-regional and cross-departmental mutual recognition of e-seals. Enterprises operating across provinces can expect improved interoperability between government and commercial platforms over time, reducing the need for repetitive paper filings.

E-seals have the same legal validity as physical company chops, unless specific laws or regulations require otherwise. This allows contracts, invoices, HR documents, and internal approvals to be executed fully online.

Companies apply for e-seals through designated seal-issuing authorities, following procedures set by local governments or competent departments. For enterprises and social organisations, procedures may be simplified compared to traditional seal registration.

E-seals must then be produced by authorised electronic seal production units and filed with them after creation. The production process involves submitting corporate registration certificates and other supporting materials. Seal data must conform to national technical standards. Only legally established electronic certification service providers (for commercial use) or e-government certification providers (for official use) may issue the digital certificates supporting e-seals. Enterprises should ensure that their providers are duly licensed and compliant with cryptographic and data-security requirements.

If an e-seal expires, is compromised, or if the company changes name, merges, or deregisters, the electronic seal must be re-issued or cancelled through the same authority. Failure to cancel an invalid seal can result in regulatory liability.

Enterprises are responsible for secure storage, access control, and internal rules governing e-seal use. The principle of “who controls, signs, and uses it - bears responsibility” applies. Companies should integrate e-seal management into internal control systems and maintain audit trails of all digital signing activities.

Existing internal stamp (or seal) regulations should be updated before e-seals are used.

Information systems used for e-seals must comply with China’s Cryptography Law, Cybersecurity Law, and Data Security Law. Logs and operational data must be securely stored. Where state secrets are involved, confidentiality regulations apply.

The introduction of a nationwide legal framework for e-seals is a major step toward trusted digital administration and business operations in China. For foreign-invested enterprises, it offers opportunities to streamline approval processes and contract execution—provided that compliance and internal governance are properly addressed. Your Rödl & Partner experts will be glad to support in upgrading your seal governance systems.