Suppose a company sells a systems-maintenance service. Finance approves an agreement requiring payment within 30 days. Before signing, the customer asks for 60 days. Sales sends the revised version through a signing service and saves the completed PDF in the customer folder.
Everyone can see that the agreement has been signed. Only when billing begins does finance discover that the payment term differs from its approval. The questions now extend beyond who signed: who accepted the new term, and which records show that decision?
Before buying or replacing a signing application, identify where the problem occurs: contract changes, approval, signer checks or post-signing storage. That makes it possible to decide whether the process or the tool needs to change.
Where the bill stands, and what applies to existing contracts
A Government House announcement on September 29, 2026 said a draft Electronic Transactions Act had been submitted to the Cabinet. Its summary discusses electronic signatures and seals, automated contracts, electronic transferable instruments and risk-based service-provider oversight.
The announcement summarizes a proposal, rather than final statutory wording. It says the law would take effect after 180 days from Royal Gazette publication, conditional on completion of the legal process. The news date does not start that period or establish a deadline for replacing a company’s system.
Businesses do not have to wait for the bill to use electronic signatures. Current law already addresses them: section 9 addresses identification, intent and a method reliable and appropriate to the purpose and circumstances, or another method establishing identity and intent under its conditions; sections 10–12 address data integrity, evidential weight and retention. See the consolidated Act in ETDA’s law collection
Section 13/2 also already recognizes contracts formed by automated systems. The government summary should not be read as announcing their first legal recognition. Its discussion of parties being able to foresee normal system operation describes a proposal; the draft text and eventual final wording still need checking.
Start by checking whether signed agreements match their approved versions and whether records explain any changes. The workflow below is Enersys’s recommendation, rather than a new statutory checklist. Adapt it to the transaction, specific laws and the company’s approval authority.
Identify the approved version before sending it for signature
Call the agreement with the approved 30-day term v1, and the customer’s requested 60-day revision v2. The versions contain different commercial terms. Approval of v1 does not establish whether finance accepted 60-day credit in v2.
In the proposed process, sales records the requested change and attaches a comparison. Finance considers the 60-day term within its authority. Legal reviews any effect on other contract clauses. The contract coordinator then sends the newly approved version to the authorized signers. Approval should identify a particular file or version, rather than an email saying “as discussed.”
If the new term has not been approved, pause the signing request. If v2 has already been signed, do not edit the PDF back to 30 days or overwrite the file to match accounting records. Preserve the original files and correspondence, then refer the matter to authorized decision-makers and legal. A departure from internal approval procedure does not by itself establish that a contract has no legal effect.
The existing system may support a renewed-approval step and restrictions on file changes. If it cannot distinguish drafts from approved versions or show who changed the text, that limitation becomes a specific requirement for software selection.
Does the person using the account have authority for this agreement?
Once v2 is approved, identify the signers for both parties. Establishing who opened an email or used a signing account helps establish identity. It does not fully answer whether that person may bind the company on these terms.
For example, if a company’s signing conditions require two directors jointly, a signature from one is no reason to skip checking the other. If a delegate signs, check whether the mandate covers this agreement. ETDA distinguishes authorized company signers from delegated signers in its Electronic Signature Guideline, Recommendation 23-2563. This is standards guidance, rather than a statute imposing one workflow on every company.
In our example, legal or the person assigned by the company checks signing conditions and supporting documents. The record states what was reviewed, who checked it and what remains unresolved. Sales sends the request to the checked signers, rather than automatically choosing the contact who answers email fastest.
If the signer’s name differs from the reviewed information, or a mandate does not cover the transaction, seek clarification before the next operational step. Staff should not change names or add replacement documents retrospectively without preserving a history. Legal should assess agreements already signed against the facts, rather than relying on a screen status alone.
What should be kept together after signing?
The completed agreement starts the evidence set. Questions about approval and authority may require records held elsewhere. A PDF alone may therefore leave the company unable to explain what happened, even when its contract wording remains readable.
Give the hypothetical agreement a reference such as SV-001 and link the relevant records as follows. The reference and register are examples; they do not require a new application.
| Question to explain |
Records linked to SV-001 |
Responsible role in this example |
| Why was 60-day credit accepted? |
v1, v2, the change comparison and v2 approval identifying the approver |
Sales and finance |
| Who had signing authority? |
Signing conditions or mandate used for the check, with the reviewer identified |
Legal or the assigned reviewer |
| What wording did both parties sign? |
The completed file from the signing service and contractual attachments |
Contract coordinator |
| What did the signing system record? |
Available event records and signature-validation information |
IT with the service provider |
| Who may retrieve it, and when is retention reviewed? |
Storage location, access rights and the company’s retention conditions |
Records owner with legal |
This is an index of evidence, rather than an instruction to copy every personal record into one folder. It may link to repositories with different access rights. Keep necessary information and set retention according to applicable rules and the transaction’s needs, rather than accepting a software default as the answer.
Keep the original files obtained from the signing service too. Printing a fresh PDF or taking a screenshot may not preserve signature-validation data in the same way. Separate working copies from retained evidence, and ask the provider which formats support later verification.
What can the recorded times explain?
Suppose the report says the customer signed at 09:00, while the file sales received by email displays a different time. That does not establish tampering. The times may refer to different events or time zones.
IT should check the recorded event, time source, time zone and associated file version. Keep the explanation or review result with SV-001. If the discrepancy remains unexplained, record the question and request provider information instead of manually changing report times to match.
An ordinary event-log time and a timestamping service with a specific verification method are different things. Choose according to transaction risk and applicable requirements, rather than treating “timestamp” on a feature list as sufficient for every case. ETDA recommends matching the signing method to purpose and risk.
Test a provider change without relying on the original account
A more useful exercise than checking the download button is to have someone outside the negotiation explain SV-001 from exported records. Do not use the salesperson’s or administrator’s account as a shortcut. Give the reviewer access only to necessary information.
Ask which agreement was fully signed, who approved 60-day credit, what supported the signers’ authority and how the file can be checked. Then open its linked attachments and reports. If inspection works only inside the provider’s interface, ask how it will work after cancellation and whether retention or export carries an extra charge.
The exercise should produce assigned corrective work: finance confirms the credit-approval route; sales stops sending unapproved versions; IT tests exports; or legal reviews post-termination evidence access. Mark an unanswered point “not yet verified,” with someone responsible for following it up. An openable file is not a reason to mark the whole process complete.
If the existing system supports these steps, process changes may be the first investment. If necessary evidence cannot be exported, records depend on one employee’s account, or approved and signing versions cannot be distinguished, the case for a system change becomes specific. So does its acceptance test.
Questions to answer before approving the project
How can we tell whether the signed PDF supports our actual work?
Start with its intended use. For billing, finance checks the payment term against its approval. To explain who accepted a changed term, retrieve approvals and correspondence. To inspect signatures, test the file and data provided by the signing service. Different reviewers may need different evidence. An openable PDF does not answer every question, and an organized evidence set does not guarantee a legal outcome.
When should we change the process, and when should we replace the application?
If records exist but nobody owns renewed credit approval, assign the decision-maker and return route first. If responsibilities are clear but the system still permits unapproved versions to be sent, check whether permissions or a review step can prevent that. Record unresolvable limitations, such as an inability to export verification information the business needs, as acceptance requirements for a replacement provider. “Has an audit trail” is no substitute for specifying which events the team must be able to inspect.
The process owner should present the review to the project approver for specific decisions: which contract type to test, who reviews each stage, which evidence is missing and which steps await an authorized decision. Explaining who handled an agreement and when its terms changed provides a clearer acceptance test than a promise of “online signing support.”
AI-generated conceptual illustration of document and signing traceability. It is not a real system, government document or evidence of legal compliance.
Sources checked October 18, 2026: Government House announcement, September 29, 2026, ETDA’s consolidated electronic-transactions law collection, ETDA Electronic Signature Guideline 23-2563 and ETDA e-Signature FAQ. The contract example and operational review are Enersys’s recommendations, not a real customer case or a legal determination.
Discuss connecting contract approval with business data systems
