
Company stamps are a governance system, not an image
In mainland China, Japan, Taiwan, Hong Kong, and Vietnam, the company stamp - chop, hanko, seal, or 公章 - is how an organization expresses itself on paper. Digitalizing it is often misunderstood as scanning or redrawing the stamp image. It is not. A stamp is a control system: who holds it, who is allowed to apply it, which documents require it, and what evidence remains after it is applied. Moving it online means recreating those controls with cryptographic equivalents, market by market.

Company stamps across key markets
Legal requirements differ sharply: some markets mandate seals for companies, others treat them as optional custom.
| Typical stamps | Legal status | Key legal basis | Digitalization trend | |
|---|---|---|---|---|
| Mainland China | Company chop (公章) + contract/finance/invoice chops | Mandatory for most corporate acts; registered with public security | Electronic seal issued by licensed CA; Electronic Signature Law Art. 14: reliable e-signature = handwritten signature or seal | Seal controlled centrally; e-seal via licensed providers |
| Japan | Company jitsuin (実印), ginkoin (銀行印), kakuan (角印) | Registered seal at legal affairs bureau; used for registrations and major acts | eIDAS does not apply; e-signature law (2000) recognizes electronic signatures; digital admin push since 2020s reduced but did not eliminate hanko | Hanko still common in banking and real estate; hybrid workflows growing |
| Taiwan | Company seal + responsible person's seal (大小章) | Customary, not statutory for most contracts | Electronic Signatures Act recognizes e-signatures meeting its criteria; contracts do not require seals | Seals remain customary; e-signature accepted in regulated filings via certificates |
| Hong Kong | Company chop | Optional since Companies Ordinance (Cap. 622) removed the common seal requirement | CO Cap. 622 permits execution by signature; e-signature recognized; chop persists by custom | Most contracts can move to signature-only |
| Vietnam | Company seal | Not required for every contract since 2020 Enterprise Law; seal usage per company decision | Enterprise Law 2020 removed blanket seal mandate; e-signature recognized under e-Transactions Law | Many companies still stamp by choice |
What changes when the stamp goes digital
The same governance questions apply online as offline - they just need different answers.
Who holds the 'stamp'. Physically, one person holds the chop. Digitally, control means who can trigger a signing or sealing event, enforced by accounts, roles, and multi-factor authentication instead of a desk drawer. Define the digital custody rules before you choose a platform.
Who is allowed to apply it. Offline, misuse happens when the holder stamps without approval. Online, the platform's approval workflow becomes the control: document → reviewer → authorized signer/sealer, each step logged. The audit trail replaces the 'who had the chop that day' investigation.
Which documents require it. Not every document needs the same instrument. Map your document types: which need a company seal, which need a person's signature, which need both, and which need nothing. This mapping is the core deliverable of any stamp digitalization project.
What evidence remains. A stamped paper leaves the stamp and the file. A digital seal or signature leaves the visual mark plus cryptographic evidence: signer identity, certificate, timestamp, document hash, and an event log. In a dispute, this evidence is what a court or regulator will ask for.
Three digitalization paths - and which fits
The right path depends on where your counterparties are and what your documents must withstand.
Electronic seal from a licensed CA. In mainland China, an electronic seal (电子印章) issued through a licensed provider and filed with the public security organ mirrors the physical chop's role. It is the path to take when Chinese counterparties or authorities expect the seal form. In the EU, a qualified electronic seal (QESeal) under eIDAS serves the same organizational role for eDelivery, e-invoicing and public procurement.
Qualified/advanced electronic signatures for people. Where the document needs a person's binding agreement - an authorized officer, a director, a representative - use an electronic signature, upgraded to advanced (AES) or qualified (QES) where the document's stakes justify it. This is the path for contracts that previously needed a signature plus a stamp.
Hybrid: keep the seal visual, add cryptographic proof. Most cross-border businesses do not need to pick one. The document can carry the seal or chop graphic your counterparty expects while an e-signature and audit trail underneath provide the enforceability. This preserves familiarity for seal-culture partners and proof for everyone else. eSign.AI renders both layers in one PDF.
A five-step migration plan
Inventory every stamping point
List the documents your company stamps today - contracts, bank forms, invoices, filings, certificates - and who stamps each. Include the stamp types in use (company, contract, finance, invoice) and the systems where stamping happens.
Classify by legal requirement
For each document, determine what the law and the counterparty require: mandatory seal (many Chinese corporate acts), customary seal (Taiwan, Hong Kong, Japan banking), or nothing (most ordinary contracts). This decides which instrument replaces the stamp.
Pick the instrument per document class
Mandatory-seal documents in China → licensed CA electronic seal. Organizational-origin documents in the EU → QESeal. Person-bound agreements → e-signature (AES/QES by stakes). Customary-only → e-signature with optional seal graphic. Document the mapping.
Redesign the approval workflow
Define roles, delegation rules, and review steps in the platform to mirror (and improve on) your physical custody rules. Test that no single compromised account can apply the seal without the intended approvals.
Pilot, train, then measure
Run one document class end to end with real counterparties. Confirm the receiving side accepts the output - the seal renders correctly, the signature validates, the file opens everywhere. Train the teams that previously handled the physical chop, then expand class by class.
Cross-border scenarios: which instrument applies
When a document crosses a border, the stamp or signature expectation of the receiving market usually governs. Three recurring scenarios show the pattern.
A Chinese supplier signs a contract with a European buyer. The buyer's counsel may ask for a qualified electronic signature under eIDAS; the supplier's team is used to the company chop. The workable answer is often an AES or QES signature from the supplier's authorized officer, with an optional seal graphic, plus an audit trail both sides accept. The contract's governing law clause, not the stamp, decides which validity standard applies.
A Japanese subsidiary needs a parent guarantee. Japanese banks and registries commonly expect the company jitsuin on guarantees and security documents. Digitalizing this step requires either the registered seal's digital counterpart accepted by the receiving institution, or a wet-ink exception path. Confirm the receiving institution's acceptance before removing the physical step.
A Hong Kong company with mainland operations. The Hong Kong entity can execute most documents by signature alone (Cap. 622). But documents that touch the mainland - a contract with a mainland counterparty, a filing, a bank form - may trigger the mainland's seal expectations. Keep both instruments available: signature-based execution for HK-side documents, licensed electronic seal for mainland-facing ones.
Common questions
A scanned stamp image has no cryptographic link to the company or the document; it proves only that someone placed an image in a file. If the law or a counterparty requires a seal or reliable signature, you need an instrument with legal backing: in mainland China, an electronic seal issued by a licensed CA (Electronic Signature Law Art. 14 gives a reliable e-signature the same effect as a handwritten signature or seal); in the EU, a qualified electronic seal under eIDAS Art. 35.
How eSign.AI applies this in practice
eSign.AI is built for organizations that operate across seal-based and signature-based markets. The platform supports organization-level sealing and person-level signing in one document flow, with per-document instrument choice, approval routing, and a unified audit trail. If you are replacing a physical chop or hanko process, start with the inventory and classification steps above, then pilot one document class before rolling out.








