Criminal law protection of citizens’ digital identity: challenges in countering offenses involving electronic signatures in the Republic of Kazakhstan and the Russian Federation

The article examines current organizational, legal, and criminal law challenges in ensuring information security amidst the total digitalization of electronic document management in Kazakhstan and Russia. The rapid growth of digital institutions and electronic digital signatures (EDS) is accompanied by a surge in high-tech crimes utilizing social engineering, generative artificial intelligence, and digital identity theft.The authors classifymodern cyberthreats within financial transactions and analyze gaps in current substantive and procedural laws of both countries regarding the qualification of offenses against digital authentication methods. The methodological framework comprises systems analysis, the formal-legal approach, and comparative law. The scientific novelty lies in substantiating the need to recognize digital identity and electronic signatures as independent objects of criminal law protection. Based on the findings, a practical framework of interagency measures is proposed across four levels: socio-preventative, administrative-control, material-technical, and criminal-legal. Specifically, the study substantiates implementing a state SMS-notification system for EDS activity, granting prosecutors authority to conduct unannounced IT audits of personal data operators, upgrading cyber police units with Big Data laboratories, and criminalizing unauthorized Deepfake use and unlawful EDS acquisition with mandatory imprisonment.