Signature record

What it means

A signature record, in the sense of the Accounting Act, is a handwritten signature or its electronic equivalent showing who is responsible for an accounting record. An accounting document must bear the signature record of the person responsible for the transaction and of the person responsible for posting it.

The electronic form may be an electronic signature or another verifiable method, such as approval in a system that records unambiguously who approved the document and when. What matters is that the person can be reliably identified and the record cannot be changed unnoticed.

Signature records are part of the verifiability of the accounts. Without them it is unclear who approved a purchase or who posted a document, and in an audit the document can be challenged as incomplete.

How it works in practice

With digital document flow we set up approval directly in the system: a purchase invoice goes through approval by the responsible employee, whose name and time are stored, and then we post it. We regard the trail in the system’s audit log as a signature record, provided the system does not allow it to be overwritten.

Who is responsible for what is described in the internal policy on document flow. In smaller companies the director is often responsible for all transactions; in larger ones responsibility is split by department and limits.

When archiving electronic documents we make sure the approval data are kept together with the document. A bare invoice PDF with no record of who approved and who posted it does not meet the verifiability requirements.

What to watch out for

Shared logins for several people undermine the electronic signature record, because it is unclear who performed an action. Every user of the accounting and approval systems should therefore have their own account.

A document signed after the fact, for example just before an audit, raises suspicion. Approval should take place when the transaction is being dealt with. In audits the approval date is therefore often compared with the dates the invoice was received and paid.