In a word, no. The federal ESIGN law does not specify the type of user authentication to be used with e-signatures. The definition of an e-signature under ESIGN refers to user authentication in the phrase “a contract or other record . . . adopted by a person'; however, it does not specify how the signer should “adopt' the contract or record. Ideally, the choice of a user authentication method should depend on the risk profile of the organization and the process it is automating. For example, smart cards with digital certificates may make sense when signing highly sensitive military requisitions, but they are not necessary for consumers applying for a loan online. , editor_rich_content