2025-11-18 | IT Law

What Is Meant by AVDH?

According to Section 1(5) of Act CCXXII of 2015 on Electronic Administration (the “Electronic Administration Act”), AVDH is a service in which a service provider designated by law links a document submitted by the client to the client’s personal identity and electronically authenticates this link.

The term “service provider designated by law” refers to a trust service provider, as defined in Article 3(19) of the eIDAS Regulation:

“A natural or legal person who provides one or more trust services;
a trust service provider may be a qualified or a non-qualified trust service provider.”

Why Was AVDH Phased Out?

Several factors may have contributed to the phasing out of AVDH. First and foremost, the modernisation of the state’s electronic signature infrastructure likely played a key role. In addition, the legislator appears to have sought more secure, better-regulated solutions. AVDH did not strictly comply with the requirements of the eIDAS Regulation, as it did not qualify as a qualified electronic signature nor fit clearly into any of the signature categories defined by eIDAS.

FEDOR and DÁP

The implementing decree of Act CIII of 2023 (the “Dáptv.”) regulates, in Section 72/A, the newly introduced service called FEDOR (Assignment of a Document to a User), which replaces AVDH for authentication of documents after its discontinuation.

Compared to the previous regulation, greater caution is required: the FEDOR service cannot be used to create an electronic private document with full probative value; it merely attaches a presumed authenticity to the document. This means that it is presumed that the document’s authenticity has not changed since its submission. The service only verifies the data of the person who submits the document.

This is problematic because the prescribed “level of authenticity” does not reach the probative force of a full-probative-value private document. Act CXXX of 2016 on the Code of Civil Procedure provides as follows:

“A private document with full probative value shall, until evidence to the contrary is produced, constitute full proof that the person who signed the document made, accepted or acknowledged as binding the declaration contained therein.”

Accordingly, the authenticity of the document need only be proven if the opposing party disputes it, or if the court determines that verification is necessary.

A further distinction is that the FEDOR service assigns the document to the user, rather than authenticating it. This results from the fact that e-Identification within the Digital Citizenship Programme (DÁP) and the “Ügyfélkapu+” system are available only to natural persons. Thus, when using the FEDOR service, a document cannot be assigned to a company, civil organisation or other legal person. In summary, the service cannot lawfully be used when acting on behalf of a legal person, and it is not suitable for certifying representation rights.

DÁP is a mobile application introduced under the Digital Citizenship Programme that enables citizens and other authorised users to manage their administrative matters and identify themselves digitally via a mobile device. Among its services, the e-Identification function is deemed equivalent to personal appearance in administrative procedures. However, this functionality applies exclusively to natural persons.

The electronic signature feature (e-Signature), which is equivalent to a qualified electronic signature, enables users to create electronic private documents with full probative value. Registration in the mobile application and activation of the signature certificate are sufficient; users are not required to obtain a separate certificate or external signing device. The e-Signature is available exclusively to natural persons and replaces handwritten signatures for their own matters and in procedures requiring submission of a private document with full probative value. If the document is signed not as a private individual but, for example, as a company manager or attorney, the digital signature results in invalidity.

The Position of Companies

As a consequence of the changes, all economic operators must ensure that their authorised representatives hold a qualified electronic signature, in order to meet their statutory obligations relating to electronic administration and electronic communication.

In practice, this means that in procedures conducted with governmental, municipal or chamber authorities, only documents bearing a personal electronic signature or an electronic seal will be accepted.

Accordingly, the person authorised to represent the company must hold a qualified electronic signature or an advanced electronic signature based on a qualified certificate, as such signature replaces the handwritten signature and constitutes an electronic private document with full probative value. The required certificate must be obtained from a trust service provider authorised under and compliant with the eIDAS Regulation. For practical reasons, it is advisable to have the certificate registered in the companies register, as this facilitates seamless administration.

If multiple persons are authorised to sign on behalf of the company, each must hold their own electronic signature. The eIDAS Regulation provides a unified framework for electronic signatures across the European Union; consequently, every Member State must recognise qualified electronic signatures and trust services issued in any other Member State.

Submission of Documents

Documents must continue to be submitted electronically via the ePapír service, but must now be attached with a valid electronic signature.