43 reliability in the commercial sense); and the degree to which cryptography should be permitted for confidentiality purposes. 6.3.10 Different countries have taken different approaches to electronic authentication in order to balance concerns about electronic commerce, lawful state access, human rights and civil liberties, and technical security considerations. The European Parliament issued a Directive in 1999 on a Community Framework for Electronic Signatures37 aimed at enhancing the development of competitive cross-border certification providers. The certification service providers should be able to operate without the need for prior national authorisation and voluntary accreditation schemes should be developed to create a framework for the levels of trust, security and quality demanded by an evolving market. The legal recognition of electronic signatures should be based upon objective criteria and not linked to authorisation of certification service providers. In compliance with the Directive, EU countries tend not to have licensing regimes. 6.3.11 UNCITRAL develop a detailed Model Law on Electronic Signatures in 200138 to expand on the guidance given in the Model Law on ECommerce regarding signatures and to avoid the risk that different countries would develop divergent approaches to electronic signatures. The Model Law on Electronic Signatures offers practical standards against which the technical reliability of electronic signatures can be measured. In addition, it links the level of technical reliability to the legal effectiveness that may be expected from a given type of electronic signature. In this way, the legal effectiveness of a signature can be predetermined or at least predicted with some certainty, thereby enhancing the confidence of relying on electronic signatures in significant transactions. The basic rules set out in the Model Law are flexible with respect to the various parties that may become involved in electronic signatures (e.g., signatories, third parties and certification service providers). The Model Law complements the Model Law on Electronic Commerce by technical neutrality, i.e., not discriminating among the various techniques that can be used to transmit or store information.39 37 38 1999/93/EC, dated December 1999. For a review of the Working Group’s reports see: canada.justice.gc.ca/en/ps/ec/UN2000rep.html canada.justice.gc.ca/en/ps/ec/uncon98.html canada.justice.gc.ca/en/ps.ec/rf2000.html 39 The Model Laws on Electronic Commerce and Electronic Signatures should also be read in conjunction with the UNCITRAL Model Law on Electronic Funds Transfers and the Model Law on International Credit Transfers.