Can an interim or acting CEO sign contracts, including a data license?

The short answer: authority is granted, not inherited

An interim CEO can commit the company only as far as the board has authorized. The title settles little on its own; the appointment resolution, the bylaws or operating agreement and the company's delegation of authority decide what the interim leader can sign. Most interim mandates comfortably cover ordinary operations such as payroll, vendor renewals and customer orders within set limits.

A data license is rarely ordinary. It typically gives an AI developer exclusive rights to use company records for AI training for an agreed term, so the board, and sometimes the sponsor or lenders, will expect to approve it. The interim leader's job is to open the conversation, sponsor the early review and bring a clear proposal to the board.

Where does an interim CEO's signing power come from?

Read the documents, not the business card. Ask the corporate secretary or company counsel for these, roughly in this order.

The last row catches teams out. An executive placed through an interim management firm may be a contractor who was never formally appointed as an officer, which can limit what they sign until the board acts.

Interim, acting or CRO: does the label change the answer?

The label tells you how the person was appointed, which tells you where to look. It does not by itself expand or shrink their authority.

For a business inside a listed group, the parent's approval chain usually matters more than the local title; see licensing data at a public company subsidiary. The delegation of authority matrix template shows how to add a data licensing row so the question gets a written answer.

Why does a data license usually go to the board?

Because it binds the company beyond the interim's tenure and reaches records from every function. Boards tend to keep decisions like this for themselves even when the amount sits inside an officer's dollar limit.

• Exclusivity outlasts the assignment. Licenses are typically exclusive for AI training for an agreed term, which a permanent CEO and any future acquirer inherit.
• The records cross every department. Email, chat, CRM, finance and support history raise client confidentiality, employee notice and privacy questions that need sign-off.
• Proceeds may already be spoken for. Lenders or the sponsor may have rights over cash from asset-related transactions.
• A sale may be coming. Acquirers diligence existing licenses, so the deal team wants the timing to fit the process.

None of this blocks the conversation. Nothing is binding until the company agrees price and terms and signs, and the company receives one all-in price, paid once, typically within about 60 days of invoicing after the buyer selects the data. Those facts belong in the board memo.

How can an interim leader start without overstepping?

Keep exploring and committing separate. A practical sequence:

1. Spend half an hour with counsel or the corporate secretary confirming what the appointment resolution and delegation of authority say about IP licenses and exclusive contracts.
2. Tell the board chair or lead sponsor you want to assess whether the company's records could be licensed, and ask to be named the authorized representative for that review if your resolution is narrow.
3. Run a preliminary screen with the company fit checker, which needs no contact details, and compare the company with the qualification baseline: a US company with 50+ full-time employees at peak (contractors excluded), several years of documented operations and the rights to license.
4. Apply at sourcex.si/apply, or accept a partner's introduction, so SourceX can review size, history, data breadth and rights with you.
5. Lead the data inventory: which systems exist, how many years each covers and who can run exports. No records move at this stage.
6. Take the agreed price and terms to the board with a draft resolution naming the officer who will sign.

Data is delivered only after an executed agreement and the company's authorization, under de-identification and redaction rules agreed before any work begins.

What to say to the board chair

If you are the interim leader, can you also be the referring partner?

Treat it as a conflict question first. While you run the company you act for it, and a personal reward tied to a contract you are negotiating on its behalf is something the board must know about and decide on before you register; in a court-supervised case, further approvals may apply. The issues are laid out in referral fees for chief restructuring officers.

For context, partners earn 25% of the eligible platform fees SourceX actually collects from the referred company's licensing deals, capped at $100,000 per referred company. A reward becomes payable only after the buyer pays and SourceX receives its fee, it is never deducted from what the company receives, and no reward is guaranteed.

Limits and open questions

• Chapter 11. In a Chapter 11 case the company ordinarily keeps possession and control of its assets as debtor in possession (US Courts, Chapter 11 basics), so its officers still act, but ask restructuring counsel whether a license outside the ordinary course needs court approval. A related case is the non-debtor subsidiary of a Chapter 11 parent.
• Lender control. After a debt-for-equity restructuring, the new owners may hold approval rights; see who approves a data license at a lender-owned company.
• Documents and state law vary. Confirm the answer for each company with its own counsel.

This is general information, not legal, tax or financial advice. Confirm with your own counsel before acting.

Next step

If you advise the company rather than run it, confirm who can sign, then register as a partner and make the introduction. The interim leader can also apply directly at sourcex.si/apply with your referral link attached.