At its core, digitization is based on the fact that documents are stored and processed digitally “document-proof”, i.e. 1:1, i.e. the original document is replaced “legally secure” by a digital copy.
1. Modification of the document by pattern matching
In 2013, computer scientist David Kriesel discovered that XEROX uses Pattern Matching & Substitution to change JBIG2 numbers in the original document (not by subsequent OCR, but by the compression process itself). This change was not detected over 8 years, so it could have affected hundreds of millions of documents (if they contained numerical data) from other companies using the same compression method. What happens to these documents is unclear.
The Bundesamt für Sicherheit in der Informationstechnik (BSI) (German Federal Office for Information Security) has taken into account the BSI standard BSI TR-03138 Replacing Scanning (RESISCAN) – BSI Technical Guideline 03138 Replacing Scanning (BSI-Standard BSI TR-03138 Ersetzendes Scannen (RESISCAN) – BSI Technische Richtlinie 03138 Ersetzendes Scannen ) p. 23:
“Methods which use the so-called “Symbol Coding” for image compression SHOULD NOT be used”.
and footnote 29:
“If the “Symbol Coding” is inaccurate or incorrectly implemented, there is a danger that the scan result will be semantically different from the original (e.g. by swapping characters). Even with correct implementation, the necessary legal certainty cannot be guaranteed because the content and images cannot be determined with certainty”.
BSI Technical Guideline 03138 Annex V Exemplary procedural instruction p. 8 footnote 2 (BSI Technische Richtlinie 03138 Anlage V Exemplarische Verfahrensanweisung S. 8 Fussnote 2): “In particular, image compression methods based on “Pattern Matching & Substitution” or “Soft Pattern Matching”, as used for example in the JBIG2 format in accordance with ISO/IEC 14492, would be inadmissible.”
The problem lies in the wording “in particular”. The compression methods used in the various scanning procedures of the companies are black boxes, and an end user is overwhelmed with the control.
The procedures developed by the BSI guarantee the unchangeability of the document in the workflow. But what about the internal consistency?

In a court decision, the administrative court in Wiesbaden (Verwaltungsgericht Wiesbaden) commented on the scanning process: VG Wiesbaden, judgement of 26.09.2014,
6 K 691/14.WI.A ,Scanning procedure for electronic file keeping
“Insofar as the Foreigners Authority refers to the BSI Technical Guideline 03138 – Replacing Scanning, it fails to recognise that documents in official files have a meaning and documentary character. In this respect, the Federal Police not only ensure that copies of identity documents are legible when they are made, but also certify them in such a way that an official certifies that the copy corresponds to the original. In this respect, as stipulated in the technical guideline of the BSI, in the case of a substitute scan, each scanned document must be checked for its quality and signed by the person scanning it with a qualified mark of conformity.”
This is important because the focus is shifted from the standard to be certified, which concentrates on the workflow of the work process, to the appearance of the result (visual inspection, “Augenschein”).
This may seem absurd at first, since this can remain only a legal fiction with the necessary detail accuracy going down to the number and the mass scan procedures. However, the appearance  (visual inspection, “Augenschein”)reappears in the court case – there as an individual case examination.

It would therefore be necessary to disclose and license the compression procedures. Each compression would have to provide automated procedures for consistency control.

2. Enrichment of the document
Color laser scanners/printers add a color printer mark (Machine Identification Code, tracking dots) to documents to identify the machine and ultimately the creator of the copy. Whether this also happens with black-and-white scanners with other patterns has not yet been proven, but it is probable.
However, this document is then no longer document authentic because information elements have been added: it no longer corresponds 1:1 to the original.
All enrichment elements would have to be disclosed. When documents are included in document management systems, they would have to be removed automatically.

3. Conversion
Now one could say that most documents are received digitally anyway, the problem would have been solved soon. But even in a simple conversion of a Word document into pfd, the modification and creation date, author, origin and structure of the document are lost, metadata that can be important and that you might have to be able to search for. Not to mention the archiving of e-mails with document attachments, which are converted and archived in isolation, but whose context is lost.
All conversion programs would have to disclose their parameters and ensure that metadata and formatting elements are searchably transferred into the new data format.

With the german law for the promotion of the electronic administration Gesetz zur Förderung der elektronischen Verwaltung (E-Government-Gesetz – EGovG) as well as the government program “Digital Administration 2020” a time window 2020 was set for the digitization.

Let’s summarise: There are still no clear rules governing the basic principles of the digitisation process.

“You saw, O king, and behold, a great image. This image, mighty and of exceeding brightness, stood before you, and its appearance was frightening. The head of this image was of fine gold, its chest and arms of silver, its middle and thighs of bronze, its legs of iron, its feet partly of iron and partly of clay. As you looked, a stone was cut out by no human hand, and it struck the image on its feet of iron and clay, and broke them in pieces. Then the iron, the clay, the bronze, the silver, and the gold, all together were broken in pieces, and became like the chaff of the summer threshing floors; and the wind carried them away, so that not a trace of them could be found. But the stone that struck the image became a great mountain and filled the whole earth.”

Daniel Chapter 2, Verse 31