Who signs off that a scanned image is an acceptable substitute for the original record?

When an organization scans a paper record and wants the digital image to stand in for the original, someone must take responsibility for confirming that the image is a complete, accurate, and usable reproduction. That accountability is rarely a single signature on a single page. Instead, it is built into a documented digitization program with defined roles.

Who Holds the Accountability

In most organizations, responsibility is layered:

• Program owner / records officer. A designated records management official typically owns the policy that authorizes imaging as a substitute and sets the conditions under which originals may be retired. This person, or a delegated authority, formally approves the program.
• Quality control reviewer. Staff who perform or oversee scanning verify each batch against quality criteria such as legibility, completeness of pages, correct orientation, and faithful capture of color and detail.
• Management or legal sign-off. Because substituting an image for an original can affect legal admissibility and retention obligations, senior management, legal counsel, or a compliance function often must concur before originals are destroyed.

The key principle is that authority flows from an approved policy, not from an individual acting alone.

What “Sign-Off” Actually Means

A defensible substitution rests on documentation, not just a name. Strong programs maintain:

• Written imaging standards and procedures (resolution, file format, indexing, metadata).
• Quality-assurance records showing that images were inspected and accepted.
• An audit trail linking each image to its source and to the person who reviewed it.
• A retention and disposition authority confirming that originals may be destroyed once the image is verified.

Digitization standards such as those published by FADGI help define the technical benchmarks a reviewer measures against, while records management policy defines who is authorized to approve the result.

Public Sector Note

In government, agencies generally cannot retire original federal records on their own judgment; the digitization approach and any disposition of originals follow approved schedules and applicable requirements. Always confirm your jurisdiction’s rules before relying on an image alone.

For related guidance, see the digitization and imaging topic hub.