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AesirX ComplianceOne | Circular 19/2025/TT-BKHCN E-Signature Audit

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Circular 19/2025/TT-BKHCN: Scope and Current Status

What the circular covers. Circular 19/2025/TT-BKHCN sets the technical-audit requirements for e-signature and trust-service readiness. The audit covers the information systems and service-delivery processes that support:

  • secure electronic signatures;
  • digital signatures;
  • certificates;
  • trust services.

The evidence an audit produces is its scope, control records, findings, remediation and review.

Legal status. The circular is in force and applies at its own level. It does not replace or broaden the Law above it. Confirm how it applies to your organisation, and how to read it, with qualified advisers.

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How Circular 19 Relates to the E-Transactions Law

Circular 19 sits under the Law on Electronic Transactions No. 20/2023/QH15. The Law sets the legal baseline for electronic transactions, signatures and trust services. Circular 19 adds the technical audit of the systems and service-delivery processes behind them.

In ComplianceOne, your audit records link to the Law and to the neighbouring decree and circulars. The Law's own obligations are not copied into the circular, and each instrument keeps its own status.

Operational Provisions and Evidence

Operational AreaComplianceOne Support
Audit scopeDefine which information systems and service-delivery processes are subject to technical audit before you schedule a review
Findings and remediationRecord findings from each audit — the first audit, periodic audits and any voluntary audit — and the actions that fix them, against the technical-control documentation they test
Working documentsKeep internal audit-readiness records. Circular 19 has no annex and prescribes no official form. Article 7 lists what the technical-audit report must contain, and the designated audit organisation issues that report
Audit readinessKeep the trail of scope, findings and remediation ready for the next audit
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How ComplianceOne Supports Circular 19 Compliance

You run the technical audit Circular 19 requires, from scope and control records to findings, remediation and review. Circular 19 prescribes no official form of its own, so these are internal audit-readiness records, each labelled as an AesirX working document.

Nothing from Circular 19 is presented as an official filing. Where audit evidence later supports a Decree 23 or Circular 53 filing, ComplianceOne helps you build that instrument's own package for the authority or an auditor.

Circular 19 sets no trust services list and no submission channels of its own. The certificates, providers and verification checks an audit tests are recorded under Decree 23. So an audit finding points at a named credential, with its own issue, suspension, revocation and expiry history, not at a status in a spreadsheet.

Built for E-Signature Technical Audit Compliance Operations

No invented forms. Circular 19 prescribes no official form, and ComplianceOne does not make one up. Scope, findings and remediation stay in internal records labelled as AesirX working documents.

Evidence that links both ways. Audit evidence links back to the Decree 23 certificate and signature records it tests. It links forward to Circular 53's data-message certification evidence where the same trust-service systems are in scope.

Audit cycles you can follow. Circular 19 sets a first audit within one year of certification (Article 4(3)) and periodic audits every two years after that (Article 4(2)). Providers already operating when it took effect have their own first audit (Article 15(2)), and voluntary audits are allowed (Article 2(2)). Each audit is tracked as its own event, so a reviewer can see when the last one closed and when the next is due.

Status on the day that mattered. A finding about a certificate points at that credential's history. An auditor reads its status on the date in question, not its status today.

Compliance Readiness Checklist

Confirm that Circular 19 applies to you and check its current status.

Assign accountable owners and reviewers.

Keep audit-readiness records as internal working documents, since Circular 19 prescribes no official form.

Link supporting evidence and related framework records.

Record human review and approval.

Keep the audit history for later inspection.

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See Circular 19 Compliance in Action

See how ComplianceOne organizes Circular 19 evidence, audit activities, review history, and related framework records within a single operational workspace.

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Ronni K. Gothard Christiansen

Ronni K. Gothard Christiansen - Technical Privacy Engineer & CEO

Technical Compliance Expert, 32+ Years Open Source Advocate, X-BoD Open Source Matters Inc.

Or contact via

ronni@aesirx.io+84 909 500 760

Frequently Asked Questions

Yes. It has applied since 1 January 2026, and ComplianceOne tracks it separately from draft, planned and neighbouring instruments.

It adds the technical audit that tests the systems and service-delivery processes behind Decree 23's certificates and signatures. In ComplianceOne it keeps its own status, evidence and review.

Circular 19 prescribes no official form, so there is no authority-issued form to tell apart. ComplianceOne supports the audit with internal records for scope, findings and remediation, labelled as AesirX working documents.

No. The circular has fifteen articles and no annex. Article 7 sets out what the technical-audit report must contain, such as the audit scope, the findings, any nonconformities and the conclusion on conformity, but it prescribes no form for it. ComplianceOne supports the technical audit with internal audit-readiness records.

No. It organises evidence, ownership, workflow and review. It does not guarantee compliance, certification or acceptance by an authority. Your organisation remains responsible for legal interpretation.

Yes. Audit-readiness records link to Decree 23's certificate and signature evidence and to Circular 53's data-message certification records. Each keeps its own framework and audit history.

 

Next Steps

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Start a Compliance Pilot

See how ComplianceOne supports Circular 19 operational evidence, workflow, and review.

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Discuss Your Compliance Needs

Discuss how Circular 19 fits into your broader compliance program.