Who signs off before an agency deploys a new electronic recordkeeping system?

Deploying a new electronic recordkeeping system is rarely one person’s decision. Because these systems must capture, protect, and dispose of records in line with law and policy, most organizations require sign-off from several roles before go-live. The exact titles vary, but the responsibilities are consistent.

Who typically signs off

• Records management officer (or agency records officer). This role confirms the system can apply approved retention schedules, preserve records and their metadata, and support lawful disposition. In federal agencies, the designated records officer is central to this review.
• Chief information officer / IT leadership. They verify the system fits the technical architecture, can be maintained, and supports long-term access and migration as formats and platforms change.
• Information security officer. Security review confirms access controls, audit logging, and protection of sensitive content. In government settings this often ties to a formal authorization to operate.
• Privacy officer. If the system holds personal information, a privacy review checks that collection, use, and safeguards meet applicable privacy requirements.
• Legal counsel and the program/business owner. Counsel weighs litigation-hold and discovery needs; the business owner confirms the system meets operational requirements and accepts the residual risk.

A senior accountable executive frequently provides the final approval, signing off on the combined recommendation from these reviewers.

What they are actually approving

Sign-off is not just a signature on a purchase. Reviewers are confirming that the system meets recordkeeping requirements before records start flowing into it. Internationally, ISO 16175 describes the functional requirements records systems should meet in digital environments, and many approval checklists trace back to principles like these.

Why the layered review matters

Records created in a non-compliant system are difficult to fix later. If retention cannot be enforced, audit trails are missing, or records cannot be exported when the system is retired, the organization risks losing evidence, failing audits, or being unable to respond to requests. The coordinated sign-off is meant to catch these gaps before deployment, not after.

For agency-specific roles and responsibilities, see official records management policy and guidance, and explore related material on the electronic records hub.