First of all, it must be taken into account that, when a person presents paper documentation, an authentic copying process must necessarily be carried out so that the records and administrative files are electronic.
Secondly, the authentic copying process consists of the secure digitization of the documentation by a competent body with a guarantee of the identity of this body and the content, for which an electronic signature is incorporated from among those provided for by the regulations (as well as the relevant metadata).
That said, it is important to note that the regulations enable two ways to make these copies, an important fact when selecting the signature mechanism to use; namely:
- Through an authorized official, who signs with the signature mechanism at their disposal (for example, a T-CAT).
- Through an automated administrative action, which will be signed with an organ seal or with a Secure Verification Code (CSV).
It is the decision of each Administration to determine how the copying process will be carried out within its organization, taking into account the material and personal resources it has, etc.
However, the signature with an organ seal has the advantage of administrative efficiency because a person does not have to intervene in each process and allows the automation of certain steps in the digitalization process.
The system security of this option is based on access control, process supervision and records of operations associated with each person.
Law 39/2015: art. 16 and 27
Law 40/2015: art. 40 to 43
RD 203/2021: art. 19 to 22 and 47
National Security Scheme
National Interoperability Scheme
AOC Certificate Catalog : T-CAT and Electronic Seal Certificate (Organ Seal)

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