The main sources of data used in this study are as follows:

Source ofLegalandRegulatory Text:Electronic Signature Law No. 5070 [7], publications of Information Technologies and Communication Authority (BTK) regulations [8]-[10], and Prime Ministry circulars concerning the Public Certification Authority [11]. International Standards:EU eIDAS and eIDAS 2 regulations [12][13], ETSI standards (EN 319 4xx series) [14][15], ISO/IEC 14888 [16], and ITU-T X.509 recommendations [17]. Technical Reports and Guides: NIST and NCCoE publications, reports on PQC transition [1][18], and Informatics and Information Security Research Center (TÜBİTAK BİLGEM) (Public Certification Authority) technical guides [19]. Academic Literature: Research addresses comparisons of RSA and ECC effectiveness and the legal perspective of e-signatures in Türkiye [1]-[6][20].

Comparative analysis was applied to the collected dataset. Comparing Türkiye’s legal framework with EU regulations revealed gaps. The technical performance parameters of the cryptographic algorithms were compared with respect to their theoretical security levels (bit strength) and practical performance indicators (signing speed and key size). Finally, a SWOT analysis was conducted to assess Türkiye’s readiness for ECC transition.

Since 2004, Law No. 5070 of Türkiye has been the backbone of the country’s legal system for electronic signatures. It elaborates on the notion of a “secure electronic signature,” “qualified electronic certificate” (QEC), and “time stamp,” and accordingly states that a secure electronic signature receives the same legal significance that a handwritten signature does [7]. This regulation also governs Electronic Certificate Service Providers (ECSPs).

The Information Technologies and Communication Authority (BTK) is the agency responsible for regulating ESHS and establishing technical specifications. Secondary regulations, such as the “Electronic Signature and Certificate Services Regulation” [9], define ESHS responsibilities concerning key generation, storage, and key physical security. These regulations provide a stable, dependable infrastructure.

Kamu SM, set up in TÜBİTAK BİLGEM, is the root certificate authority for all the public institutions in Türkiye. It issues qualified electronic certificates to public officials and manages the lifecycle of certificates in its e-government ecosystem [19].

eIDAS (Regulation [EU] No. 910/2014) establishes standard rules for legal frameworks for electronic identification and trust services (including electronic signature, seal, timestamp, electronic delivery service, etc.) within the European Union [12]. Regulation (EU) 2015/1509 sets out minimum requirements for qualified electronic signatures and trust service providers [14].

eIDAS 2.0 (Regulation [EU] 2024/1183) defines the European Digital Identity Wallet, which will provide citizens with an opportunity to carry and make use of their digital identity assets within a secure environment using smartphones [15]. Through the stored secret in the hardware keys of such wallets, electronic signatures and identity authentication are completed [15].

It is established that Türkiye’s electronic signature laws, in general, are compatible with eIDAS, especially in connection with qualified electronic signatures, ESHS criteria, and legal aspects of electronic signatures [1]. Nevertheless, Türkiye needs to develop more legislation and technical infrastructure for the digital identity wallet, mobile signature, and cross-border recognition as defined under eIDAS 2.0.

RSA security relies on the Integer Factorization Problem (IFP), whereas ECC depends on the Elliptic Curve Discrete Logarithm Problem (ECDLP). ECDLP is exponentially more challenging than IFP for the same key size, allowing ECC to offer similar security with far fewer keys than RSA.

According to NIST recommendations, achieving a 128-bit security level (comparable to AES-128) requires a 3072-bit RSA key, whereas ECC requires only a 256-bit key (e.g., the P-256 curve) [18]. This discrepancy becomes even more glaring at higher security tiers; at 256-bit security, RSA must use a practically impossible 15360-bit key, while ECC requires only 521 bits.

ECC’s efficiency compared to RSA has been demonstrated in multiple studies. As Table 1 shows, ECC takes less time for signing, retains keys far more efficiently, and uses less memory and storage than RSA [2][3]. The data presented in the table have been derived from a compilation of the cited literature and various field tests.

Table 1.Performance comparison of RSA and ECC algorithms.

The performance metrics of ECC demonstrate its effectiveness in resource-constrained environments such as mobile devices, smart cards, and Internet of Things sensors [4]. ECC is also advantageous for large-scale key generation operations. According to [3], minor key and signature sizes during the certificate lifecycle are said to be cost-effective for bandwidth and storage by diminishing the sizes of CRL and OCSP responses. RSA is the default in many legacy systems because it is older and more extensively used than the others. Nevertheless, current libraries and systems provide mature support for ECC. Mainly, web browsers and modern operating systems have native implementations of TLS certificates and code signatures based on ECC [1][4].

A comparative SWOT analysis was performed, based on the existing system and regulatory infrastructure, to measure how the transition to the ECC would proceed.

Strengths:Türkiye has a strong legal system characterized by a robust legal framework embodied in Law No. 5070 and the Central Public Certification Authority (Kamu SM) [11]. BTK and TÜBİTAK BİLGEM should provide the technical expertise upon which to base such a transition. Moreover, the rapid diffusion of new technologies is promoted by citizens’ adoption of e-government services. Weaknesses:The law or technical circulars in force today rely predominantly on RSA, which results in regulatory lag. There are few staff trained in ECC and current cryptographic systems. Modern elliptic curves are not supported by hardware security modules (HSM) or smart cards today, which will then require expensive hardware upgrades. Opportunities:Adherence to eIDAS 2 can enable the European Digital Single Market. ECC performs better than other cryptographic techniques, which results in better end-user experiences for mobile applications. It also opens the way toward the development of domestic ECC libraries and crypto products and the phasing out of foreign technologies. Threats:One of the biggest threats to the development of the system is that there will exist a new threat of delay in the adoption of PQC (post-quantum cryptography), and it may potentially hinder the development of PQC. Lack of any focus on ECC individually could lead to a myth of long-term absolute security without consideration of the quantum implications. Rapidly changing cyber threats and the possibility of “collect now, solve later” attacks must be mitigated.

While it has all the advantages over RSA, ECC is susceptible to the Shor algorithm on fast quantum computers [5]. This poses an authentic conundrum: Should Türkiye adopt ECC now or wait for PQC standards to develop? The analysis of data shows that we are unable to support PQC due to the fast-paced, high-performance requirements of mobile/IoT systems, and this is compounded by the fact that PQC standards (e.g., CRYSTALS-Dilithium) continue to evolve and require larger key sizes than ECC [18]. ECC therefore acts as an essential “bridge” technology in the short- and medium-term (10 - 15 years).

We suggest a hybrid strategy:

1) Transition Period:Replace RSA with ECC (P-256/P-384); reducing the bandwidth and improving mobile performance.

2) Transition Period:Hybrid certificates containing both an ECC key and a PQC key should be implemented. These certificates incorporate both a classical ECC key and a quantum-resistant PQC key within a single certificate structure as a dual-key mechanism. This dual-key architecture enables systems to continue utilizing ECC signatures, which are efficient and compatible with current verification processes, while the PQC signature ensures long-term validity against future quantum attacks [15].

3) Long Term:The complete transition should be realized once standards, as well as support for the hardware technology, are mature and the PQC algorithms have been developed.

The “European Digital Identity Wallet” (EUDI Wallet) introduced by the eIDAS 2.0 regulation has changed from card-based to mobile digital wallets for identity information. The ecosystem in Türkiye depends on physical smart cards (Turkish ID Cards and Qualified Electronic Certificates on USB tokens). Türkiye needs to develop a “National Digital Identity Wallet” architecture to enable interoperability with the EU. The ECC framework is the de facto standard for mobile wallets across all these, mainly because smartphones do not support the limited Secure Elements (SE) and Trusted Execution Environments (TEE). RSA keys are often too large to be produced and stored effectively in secure regions. As a result, it is essential to adopt ECC for a practical, interoperability-respecting national digital wallet. The wallet needs to fuse its National ID card, e-Government login details, and qualified electronic signatures into one mobile facility and be able to facilitate protocols, like OpenID Connect for federation [6].

Based on this discovery, a roadmap is also suggested for the Turkish national infrastructure:

1)Policy and Regulatory Updates:Policy and Regulatory Updates: BTK should upgrade its secondary regulations to include ECC parameters and certificate profiles that are ETSI EN 319 412-5-compliant [15].

2)Root Authority Transition:All ESHSs and the Kamu SM should establish ECC root CAs, and not only the Kamu SM. To maintain backward compatibility, a parallel operational period (dual stack) is necessary, during which RSA and ECC certificates remain valid.

3)Client-Side Modernization:Middleware that is used in EBYS and KEP software, e-signature-creating applications, and libraries should be updated to process ECC keys.

4) Pilot Deployments:Pilot projects undertaken by the Kamu SM shall be extended to include mobile signatures and national ID card digital certificate functions.

5) PQC Readiness:A nationwide “Crypto Agility” inventory should be maintained to determine all crypto assets, which would allow for future upgrading of the PQC.