Electronic Documents: What to Keep Beyond the Signature

InBase's article on the legal validity of electronic documents covers required details, signatures, originals and storage. Our practical focus is the document package: what to collect, what to check separately and what to keep for later use. Ukrainian Law No. 851-IV prohibits denying a document's legal effect solely because it is electronic. Other applicable requirements still need to be met.

The legal provisions discussed here were checked on 24 September 2026. This article is for information; the requirements for a particular document depend on its type and legal context.

Keep what you actually received

Imagine a message from a partner containing a letter approving a joint project schedule, the schedule as an attachment and a separate signature file. This is an illustrative example. The sender asks for confirmation of receipt. At this stage, the employee needs to establish what the package contains and preserve the links between its parts.

First, compare the attachments listed in the letter with the files received. Record anything missing and ask for clarification. Opening the main file does not establish that the package is complete. Also identify exactly what has been signed: the letter, the attachment or a container holding both.

Article 5 of Law No. 851-IV defines an electronic document in terms of electronic data and required details. Article 7 links its status as an original to those details, including the author's signature or a signature equivalent to a handwritten one. A readable file on screen does not replace checking these conditions.

In our example, we recommend keeping the following items together, with their relationships recorded. This is an organisational recommendation, not a universal list of files prescribed by law:

• Received documents. The letter and attachments in the form in which they arrived.
• The signature and what it covers. The detached signature or signed container, with a record of the files it relates to.
• Covering message. The correspondence explaining why the materials were sent and what was included.
• Receipt details. Available information about the sender, delivery channel and time, together with related acknowledgements.

Read the verification result, not just the status

The Central Certification Authority's instructions distinguish a signature packaged with the data from a detached signature. For the detached-signature verification method described, the original signed file is also needed. In our example, that means using the pair of files actually received.

Use a verification tool that meets your organisation's rules. Check which file was verified, who is named as the signatory, the certificate details and the result. If the tool reports a problem or gives an inconclusive result, record it and refer the issue to the responsible specialist. Do not replace the tool's findings with an assumption.

Under Article 18 of Law No. 2155-VIII, a qualified electronic signature (QES) has the same legal effect as a handwritten signature, with a presumption of equivalence. Articles 17 and 18 also prohibit rejecting a signature or seal solely because it is electronic or does not meet the requirements for a qualified signature or seal. The required form depends on the rules applicable to the document.

Signatures and seals serve different purposes. Article 6 of Law No. 851-IV links a signature to the author's identity and a seal to origin and integrity; it describes completion of an electronic document through a signature and/or seal. Do not apply the rules for one document type to every other type, or assume that signatures and seals are interchangeable in all circumstances.

Keep the verification result for later reference, alongside the files themselves. In the document's record, note the tool used, the date, the result and any unresolved questions. The next person handling it can then see what has been done and what still needs attention.

A name does not establish authority to act

In our example, a person has signed the schedule. The next question is whether they had authority to approve it on the partner's behalf. Their name in a technical verification result does not, by itself, answer that question.

Part 2 of Article 207 of the Civil Code provides for a legal entity's transactions to be signed by people authorised under its founding documents, a power of attorney, the law or other acts of civil legislation. Authority to represent an organisation can have different grounds, so requiring a power of attorney from every signatory would also oversimplify the rules.

Who signed, whether they had authority and whether the content was approved are separate questions.

As an organisational step, assign someone to check whom the signatory represents and the basis of their authority. Where there is doubt, ask a specific question: did that authority cover approval of this schedule on the relevant date? Do not automatically mark the document as invalid because the answer is missing; refer the question for legal assessment.

Review the content separately too. Is this the schedule the team expected? Does the attachment contain a different version or unfamiliar terms? A technical verification result does not mean that the organisation has reviewed and approved those terms.

Receipt and a decision are separate events

The general rule in Article 11 of Law No. 851-IV is that a document is deemed received when its author receives an acknowledgement from the recipient. The law expressly allows legislation or a prior agreement to provide otherwise. If no acknowledgement procedure has been agreed, the acknowledgement must state the fact and time of receipt and identify who sent it.

In practice, agree in advance on the exchange channel, the form of acknowledgement and how it will identify the document concerned. Check what your system's status labels actually mean: sent, delivered, opened or something else. The same words in different interfaces do not establish the same rules for exchanging documents.

Record the decision on the document separately: who reviewed it, what they decided and where the outcome is stored. An acknowledgement of receipt should not take the place of the action the responsible person needs to perform.

Check that the whole package can be recovered

Article 13 of Law No. 851-IV requires electronic documents to be stored in a form that allows their integrity to be checked. It also requires accessible information, the ability to recover the relevant format and retention of available information about origin, destination and the time of dispatch or receipt. The retention period must be at least as long as that required for the corresponding paper documents.

To support these requirements, ask the team to try recovering the test package. Check the full process, from finding the record to opening the linked materials. Include these organisational checks:

• Completeness. The letter, attachments and associated signature data can all be found, and their relationships are clear.
• Repeat verification. The necessary files and data are available, and any problems are referred to the designated specialist.
• Review history. Receipt, checks on authority and decisions on the content are recorded separately.
• Responsibility. It is clear who handles storage, access, recovery and unresolved questions.

Start with one intake workflow and a test document package. Record any files, links or answers that are missing when you check it. This gives you a concrete starting point for discussing electronic document management with IQusion.

Frequently asked questions

Sources

• Legal Validity of an Electronic Document in Ukraine: Laws, Requirements, and Practice 2026
• Law of Ukraine "On Electronic Documents and Electronic Document Management" No. 851-IV
• Law of Ukraine "On Electronic Identification and Electronic Trust Services" No. 2155-VIII
• Civil Code of Ukraine: Articles 207, 237, 244
• Questions and Answers: How to Verify a Signature on a Document