Alternative evidence for wet signatures
This guidance applies to evidence for learners who are funded through apprenticeship, 16 to 19 education, adult education budget (AEB
) and advanced learner loans funding rules.
It is expected that where providers already have a digital/electronic signature process, they must continue to utilise their existing processes in accordance with the respective funding rules above for 16 to 19, adults and apprenticeship learners.
A wet signature is created when a person physically ‘marks’ a document. Where a provider has no digital or electronic systems and processes in place to capture a learner or employer signature, then under normal circumstances a wet signature is required for recruitment and evidence of continuing learning.
It is recognised that providers delivering training and/or recruiting learners during the COVID-19 pandemic will experience difficulty in obtaining learner and employer wet signatures. Therefore, for the funded programmes listed above, where providers do not have systems and processes in place for electronic/digital signatures, during the COVID-19 restrictions, we will allow confirmation and evidence to be obtained through email as detailed below.
For the purpose of audit evidence, we expect a record of acknowledgement or adoption of a genuine electronic message or document. Acceptable alternative evidence includes:
- an email from the learner and/or employer email address with details of the confirmation and their typed name at the end of the message
- a typed name on an electronic form or document emailed from the learner and/or employer
- a signed scanned document attached to an email from the learner and/or employer
- a photo taken on a camera/digital medium of the signed document attached to an email from the learner and/or employer
We are allowing providers to use this type of electronic confirmation (as detailed above) during the period of restrictions due to COVID-19 only where no other useable digital or electronic processes exist. This is not to be used as alternative evidence as part of the provider’s business as usual process once the COVID-19 restrictions are lifted.
Following the period of COVID-19 restrictions, providers using the above alternative evidence must resume their usual process for obtaining wet signatures on relevant documentation. Providers must ensure that all alternative evidence replacing wet signatures received during the COVID-19 restrictions is genuine and irrefutable, and the evidence is retained for audit purposes.