What’s New?

The last time I wrote about ELBs and Electronic Signatures was in 2022. Since then, many things have changed. Conduce has gained lots of new customers around the world and our flights per day of genuine, fully approved, paperless Tech Log pages (TLPs) with eTechLog8 has skyrocketed! With so many successful projects, we’ve spoken to lots of authorities about Electronic Signatures and continue to see the Conduce Sign on Glass approach approved time and time again.

Regulations and Guidance materials

In the European Union we have seen the adoption of eIDAS across all industries. This is the EU regulation that applies to electronic signatures (not just in the Aviation Industry).

In May 2023 EASA published updated Guidelines on the use of electronic documents, records, and signatures. This adopts the EU eIDAS regulations and terminology for the digitalisation of Aviation documents (including, but not limited to ELB/ETLs).

In April 2024 IATA have published A Roadmap for an Airline Implementation of Electronic Logbook / Technical Log which Conduce were asked to author. This was shared around the industry for comments and represents best practice and provides advice on discussion topics specifically related to the implementation of ELB/ETLs.

Some Definitions

This is a complicated subject, and in aviation we love our acronyms! So here’s some definitions so we’re all on the same page.

Item	Definition
eIDAS	eIDAS is the name commonly used to refer to Regulation (EU) No 910/2014 of the European Parliament and of the Council of 23 July 2014 on electronic identification and trust services for electronic transactions in the internal market and repealing Directive 1999/93/EC It’s the EU regulations on Electronic Signatures relevant to all industries.
EASA	European Aviation Safety Agency. EASA are the regulatory body that all national aviation authorities are governed by within the EU. Many countries outside of the EU use EASA standards as best practice.
IATA	International Aviation Transport Association. IATA is a trade association, not a regulatory body. IATA provide best practice and idea sharing within the industry.
Electronic Signature	This is an electronic form of a handwritten signature.
Digital Signature	This is a signature where metadata (not the signature itself) is cryptographically validated. Usually this requires an internet connection and is not practical for the operational environment of ELB/ETLs.
AES	Advanced Electronic Signature. This is an electronic signature which is uniquely linked to the signatory, capable of identifying them, created using electronic signature creation data that the signatory can use under their sole control, and linked to the signed data in such a way that any subsequent change is detectable. This is the level of signature required for ELB/ETLs.
QES	Qualified Electronic Signature. This is a digital signature that has all the attributes of an AES but additionally uses a qualified certificate issued by a qualified trust service provider to validate the signature. This basically means each signatory has a unique token (e.g. a smart card or USB drive) with a private key, and a corresponding certificate on the signature creation device.
Sign on Glass	Sign on Glass means the signature on the device is captured exactly in the same manner as it would be captured on paper, using a dedicated stylus on a glass device screen. This means the signature has the same validity as a handwritten signature. Conduce uniquely hold a lifetime licence from Rolls Royce to use a Sign on Glass signature for an ELB/ETL.

What’s required for ELB/ETLs?

Before 2023, under EASA Rules Conduce had identified paragraph (g) of the AMC3 SPA.EFB.100(b)(3) as the specific EASA rule applicable to electronic signatures. This states explicitly that “a certified electronic signature is typically not required”.

In the newer guidance, EASA have replaced the terminology of Certified Signatures with QES in accordance with eIDAS regulations. Therefore, we can understand that a QES is not required for ELB/ETL/EFB signatures.

In June 2024 Conduce were invited to attend the IATA ELB/ETL Airline Forum, where best practice and experience was shared by eleven airlines and four ELB/ETL vendors. We discussed topics from iOS vs Windows to Native vs Connected, but most excitingly we got to speak to representatives from the FAA and EASA on this topic.

The EASA representative, Alberto Fernandez-Lopez, had been involved in the Guidelines on the use of electronic documents, records, and signatures (May 2023) and stated unequivocally that that under this guidance an Advanced Electronic Signature (AES) should be more than sufficient specifically for Electronic Technical Logbooks.

How does Conduce Sign on Glass meet AES?

In eIDAS Section 4, Article 26 we have the requirements for an Advanced Electronic Signature.

Conduce’s Sign on Glass meets all of these requirements. Let’s see how.

Why not use a Qualified Electronic Signature?

Based on the conversation with EASA at IATA, Conduce does not believe that any authority should require an QES for eTechLog8. In fact, the Guidelines on the use of electronic documents, records, and signatures explicitly states

“The assurance level of a signature must match the criticality of the document and reflect the needs of the receiving party or of a yet-unknown third party to validate the authenticity of the signatory without being over-burdensome on administration”

An AES is simply an electronic form of a handwritten signature along with some key attributes – as demonstrated above. A QES is a digital signature with an encryption mechanism for giving the electronic signature extra security. There are several reasons why digital signatures are not suitable for ELB/ETL solutions, but a key blocker is that a digital signature requires an internet connection. In contrast, an ELB/ETL solution must be fully native. This means it should work seamlessly with or without an internet connection. If the solution is not native it can cause expensive delays or become a safety issue. A digital signature isn’t practical for the operational environment of an ELB/ETL.

It’s also worth considering what we are really protecting with a QES? Engineers and Pilots already go through extensive checks and training and must be in a secure airside area to get access to the aircraft and it’s ELB/ETL. If a bad actor gets into this arena, it’s extremely unlikely they would choose to sabotage an operation by a false ELB/ETL entry. All of the existing processes that protect the paper logbook continue to apply with an ELB/ETL, but many additional safety benefits are added!

Conclusion

Currently, we trust any authorised engineer or pilot to stamp or write their authorising ID number and make a handwritten signature to release or accept the aircraft. So, by that logic we must agree that an electronic signature with the exact same attributes is completely acceptable in an ELB/ETL.

eTechLog8 is unusual in the ELB/ETL market because we capture the handwritten signature as a “Sign on Glass” action. “Sign on Glass” means the signature on the device is captured exactly in the same manner as it would be captured on a standard paper technical log, using a dedicated stylus. The electronic use of a handwritten signature for an ELB/ETL is patented by Rolls Royce and Conduce uniquely has a lifetime licence from Rolls Royce to use a handwritten signature for an ELB/ETL.

Other ELB/ETL vendors and Airlines have come up with different approaches for electronic signatures but at Conduce we have kept it simple and followed the same approach as the handwritten, wet ink signature, whilst meeting all the requirements for an AES as per the EASA guidance. We think this simple principle is why Conduce have never failed to get eTechLog8 approved with an Aviation Authority!