Three such
approaches appear: a prescriptive
approach that requires the use of digital
signatures, based on a «false promise» of equivalence to manuscript
signatures and «incorrect assurances that digital
signatures are secure»; a
minimalist approach that does not prescribe any technology, though some countries have followed UNCITRAL in requiring that e-
signatures be appropriately reliable; and a hybrid or two - tier
approach that allows e-
signatures at large for some purposes and requires digital
signatures for others.