In the context of Covid-19 and increased remote working, we have been asked about the acceptability of electronic rather than ‘wet’ signatures (ie signing a document by hand using a pen) in relation to the submission of forms and other regulatory documents to us.
In the absence of any specific legal provisions to the contrary, we confirm that firms may use electronic signatures for such purposes, although we may in specific instances request a ‘wet signature’ where it is appropriate to do so.
We will review this approach in the light of evolving working practices, while recognising that many forms are already processed on an automated basis.
We are unable to comment on the use of electronic signatures more generally, and firms should obtain their own legal advice on the validity of such signatures in specific circumstances. PRA-regulated firms are reminded of Fundamental Rules 1-3 and 5-7 and other parts of the PRA Rulebook concerning the adequacy of systems and controls.