
On July 11, the Vietnam Banking Association held a meeting to comment on the draft Decree on electronic signatures and trusted services with credit institutions.
Vice President and General Secretary Nguyen Quoc Hung said that in the past, the Banking Association, together with its member organizations, had contributed many opinions and documents to the draft Decree on electronic signatures and trusted services. Most recently, the Association sent Official Dispatch No. 332/HHNH-PLNV to the Ministry of Information and Communications.
At the meeting, representatives of credit institutions said that currently, banks are applying 2-layer security and 2-factor authentication to ensure that the person performing the transaction is the account owner. From July 1, banks will simultaneously deploy an additional biometric authentication step according to Decision 2345 to ensure the highest level of safety for customers. If the digital signature is added, it will greatly affect banks, the customer experience, and increase costs for both customers and banks.
Specifically, when applying digital signatures, in addition to banks increasing costs when investing in infrastructure to connect with digital signature service providers (CA); greatly increasing costs for society when customers have to pay for digital signatures, pay annual fees...
Technically, banks and CA providers are currently using different technologies. Implementing digital signatures will force CAs to connect with each other and with all banks. For example, if a bank only registers Viettel's digital signature without connecting with FPT, it will force the bank to connect with FPT.
Along with that, if banks have to use digital signatures instead of OTP as in the draft Decree, previous online transactions will now require an additional step of connecting to the CA provider to authenticate the transaction. This leads to concerns among credit institutions: can the connection infrastructure of CA providers authenticate the number of transactions up to billions of transactions per year, about 500 signatures/second in a bank? In case that technical requirement is not met, this authentication step can lead to a delay in transaction time, leading to the risk of transaction congestion...
The representative of the Legal Club of the Banking Association said that the application of digital signatures will have a huge impact on customers' money transfer orders. If all customers use digital signatures, when customers transfer money, the bank will have to confirm the transaction, recheck the data, transfer the data for verification to the CA, and the CA must respond to this verification in a very short time, just a few seconds. With billions of transactions, the CA's ability to respond is very difficult.

From the above shortcomings, credit institutions recommend that people should be allowed to proactively choose digital signatures according to their needs. If they must use them, they must be systematic, using the same digital signature for all activities from banking transactions to public and administrative services; focusing on one platform so as not to affect customer experience; combining a single point of contact to connect and minimize costs; giving banks time to prepare before deployment...
In addition, credit institutions also propose to use specialized electronic signatures to ensure safety for internal activities; as well as represent that organization in transactions with other organizations and individuals, create and provide electronic signatures for other organizations and individuals to use in transactions with that agency or organization, in accordance with the functions and tasks prescribed by law.
Appreciating the opinions at the meeting, Vice Chairman and General Secretary Nguyen Quoc Hung said that after the meeting, the Banking Association will summarize all opinions, as well as data on the specific impacts of each bank when using electronic signatures compared to specialized electronic signatures to ensure safety, to send to the Drafting Committee and state management agencies for consideration, to absorb the opinions of credit institutions and make adjustments so that the Decree when issued is suitable to reality.
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