7.2 RON Authorization Requirements

Authorization Is Layered on an Existing Commission

RON authority in Pennsylvania is not a separate commission. It is an additional authorization a person adds to an existing notary commission. A RON notary is therefore first a fully commissioned Pennsylvania notary — appointed by the Department of State, having met the education, examination, bond, and registration requirements — and then notifies the Department of the intent to perform electronic and remote acts.

Because the authority is layered, it is bounded by the underlying commission: when the four-year commission expires or is revoked, the RON authority ends with it, and the notary must re-establish electronic/remote authority with each renewal.

The Notification Requirement

The central statutory gateway is notification. Before a notary performs a notarial act with respect to an electronic record, or performs a notarial act for a remotely located individual, the notary must notify the Department of State that he or she will be doing so. This is a pre-condition: a notary who simply downloads RON software and starts notarizing without first notifying the Department has not lawfully obtained RON authority. The notification is made through the Department's online notary system.

Identifying the Technology Provider

Notification is not generic. As part of notifying the Department, the notary must identify the communication technology, and any technology provider, that the notary intends to use. The Department maintains a published list of Approved Electronic and Remote Notarization Solution Providers, and the technology the notary names must conform to the Department's standards. If a notary later changes platforms, the notary must update the Department with the new technology being used.

Requirements the Communication Technology Must Meet

What "Tamper-Evident" Means

A core requirement is that the technology produce a tamper-evident electronic record. "Tamper-evident" means that any change made to the electronic record after the notarial act will be detectable. This is how an electronic notarization preserves the integrity that a wet seal and ribbon historically provided on paper. The same standard extends to the electronic seal and signature, which must be independently verifiable and attached to the record in a way that reveals subsequent alteration.

Electronic Notarization vs. Remote Notarization in the Notification

One subtlety students overlook: the notification covers two related authorities that are not identical. A notary may notify the Department that they will perform notarial acts on electronic records (electronic notarization, where the signer is still physically present) and/or that they will perform acts for remotely located individuals (true RON). Many notaries notify for both at once because RON inherently involves electronic records, but the statute treats them as distinct authorities.

The exam may ask which authority a given scenario requires: a signer in the same office signing a PDF needs only the electronic-record authority; a signer appearing by video requires the remote-individual authority as well.

Steps to Become RON-Authorized

Use this sequence to anchor the order of operations, which is frequently tested:

1. Hold a valid Pennsylvania notary commission in good standing.
2. Select an approved communication-technology provider from the Department's approved list.
3. Notify the Department of State through the online system of the intent to perform electronic and/or remote notarial acts, identifying the technology and provider.
4. Begin performing RON only after the notification is on file and the technology meets the standards.
5. Update the Department whenever the technology or provider changes.
6. Renew RON authority with each commission renewal — it does not survive a lapsed commission.

Bond and Underlying Requirements

The takeaway is that RON adds a technology and notification layer, not a second bond or second commission.

Practical Setup Pitfalls

Several avoidable mistakes cost notaries their RON authority or expose them to liability. First, acting before the notification is on file: a notary who performs a remote act before the Department has the notification has performed an unauthorized act, even if the technology was perfectly adequate. Second, using a non-approved platform: a generic video-conferencing tool that lacks credential analysis, dynamic KBA, tamper-evident sealing, and recording does not meet the standard, no matter how clear its video is.

Third, letting the commission lapse: because RON is layered on the commission, a notary whose commission expires loses RON authority instantly and must re-establish it on renewal. Fourth, failing to update the Department after switching providers: the technology on file with the Department should match the technology actually used. Building a habit around these four checks — notification filed, approved platform, commission current, provider on record — prevents the most common compliance failures.

Exam Focus

• A notary must notify the Department of State before performing electronic or remote acts.
• The notary must identify the approved technology/provider used.
• Technology must deliver two-way sight and sound, tamper-evident records, and support two identity-proofing processes.
• RON authority is tied to the underlying commission and renews with it.