Common questions concerning Permanent Changes to 

Acceptable Signature Requirements on Retirement 

Processing Forms

1. What does OPM mean by allowing “electronic” and “digital”

signatures on retirement processing forms?

OPM will now accept forms and documents included in a retiree’s

retirement package to be electronically or digitally signed. The term

“digital signature” means a signature that has been created by software

that contains an authentication certificate and includes the individual’s

name, date and time of signature. Examples of these types of software

include Adobe Acrobat or DocuSign. The term “electronic signature”

means electronic forms/documents that contain a “wet” or digital

signature, that is made into a photocopy, converted to a PDF or other

type of electronic document, and then submitted to OPM. The two

terms—i.e., “digital signature” and “electronic signature”—may be used

interchangeably throughout this BAL and in accordance with 5 C.F.R. §

850.106.

2. Is everyone required to submit retirement forms containing

electronic signatures?

No, employees and agency personnel including Payroll offices, may still

submit original retirement forms, including but not limited to the forms

listed on Appendix A, containing valid signatures or photocopies of signed

documents directly from an official system of records in the custody of

the agency according to the procedures listed on BAL 12-102.

3. When should employees sign the forms electronically?

Employees are not required to sign retirement forms electronically.

Signing the forms with electronic or digital signatures is optional;

applicants may use this option only when they are not able to sign the

documents with a “wet,” “pen-and-ink” or handwritten physical

signature. Agencies are encouraged to create procedures that outline

when employees should use “wet” signatures on forms/documents. The
procedures should follow protocols from the Safer Federal Workforce 

Task Force’s guidance on keeping employees and agencies operating 

safely during the COVID-19 pandemic. 

4. How can employees and agencies sign the forms

electronically/digitally?

Most OPM retirement forms are Adobe Acrobat fillable forms and may be

completed and signed by PIV/CAC authentication. Other types of thirdparty software used to complete the forms or documents will dictate the

electronic/digital signature method used to sign the form. Regardless of

the method used, the electronic record must be tamper-proof once it is

electronically signed in accordance with 15 U.S.C. §§ 7001, 7021, and

7031. The most common methods used to capture an electronic signature

include:

o A handwritten signature input on a display screen using a stylus

device

o A digitized image of a handwritten signature that is attached to an

electronic record

o A PIV/ CAC authenticated digital signature.

5. What if the form I want to submit with an electronic or digital

signature is not listed on Appendix A?

Employees should contact their Agency’s benefits office to inquire about

whether a particular form not listed on Appendix A can be submitted using

an electronic or digital signature. Benefits offices should contact their

Headquarters level Benefits Officers for additional guidance. Agency

Benefits Officers are encouraged to contact their assigned OPM liaison for

guidance on submitting specific forms or documents not referenced or

listed on this BAL.
6. Can retirement forms/documents containing electronic/digital

signatures be submitted through alternate methods besides

regular mail or the Secure Drop Box (i.e., text message)?

No. At this time, OPM has not established an alternate process to accept

such forms/documents through any other submission method. Agencies

should continue to follow the existing process to report the death of a

Federal employee or submit reemployed annuitant and Phased

Employment/Phased Retirement notifications.

7. How do Agencies ensure they are following 15 U.S.C. §§ 7001,

7021, and 7031 in facilitating the use of electronic records and

signatures?

The head of each agency must establish internal guidelines and

procedures to accept and validate electronic signatures on retirement

and benefit forms. Agencies should use adequate IT systems that can

properly maintain documents that contain electronic signatures and

ensure the records are created and kept in a secure environment that

protects the records from unauthorized modification or destruction.

8. How does this BAL differ from OPM’s recent guidance on changes

to retirement application processing while operating under

COVID-19?

This BAL expands the flexibility to submit retirement application forms

with electronic signatures including the FERS/CSRS Designation of

Beneficiary (SF 3102 and SF 2808), the SF 2823, Designation of

Beneficiary (FEGLI), and the SF 2818, Continuation of Life Insurance

Coverage (FEGLI). This BAL also adds the flexibility for electronic

signatures to be created through a third-party software, such as

DocuSign, HelloSign, Adobe Sign, or other agency approved third-party

software. Additionally, this BAL removes the requirement for payroll

offices to use OPM’s secure electronic drop box to upload scanned

retirement packages. The secure drop box has been disabled and can no

longer be used to submit retirement documents.
9. Can a current or former federal employee submit an electronically

signed document to OPM’s Retirement Services without going

through their agency?

No, this BAL requires that all electronically signed forms must be

validated and stored by the employing agency. Retirement Services does

not currently accept digital signatures directly from employees, former

employees, annuitants, or their survivors.