We systematically investigate the error sources for high-precision astrometry from adaptive optics based near-infrared imaging data. We focus on the application in the crowded stellar field in the Galactic Center. We show that at the level of <=100 micro-arcseconds a number of effects are limiting the accuracy. Most important are the imperfectly subtracted seeing halos of neighboring stars, residual image distortions and unrecognized confusion of the target source with fainter sources in the background. Further contributors to the error budget are the uncertainty in estimating the point spread function, the signal-to-noise ratio induced statistical uncertainty, coordinate transformation errors, the chromaticity of refraction in Earths atmosphere, the post adaptive optics differential tilt jitter and anisoplanatism. For stars as bright as mK=14, residual image distortions limit the astrometry, for fainter stars the limitation is set by the seeing halos of the surrounding stars. In order to improve the astrometry substantially at the current generation of telescopes, an adaptive optics system with high performance and weak seeing halos over a relatively small field (r<=3) is suited best. Furthermore, techniques to estimate or reconstruct the seeing halo could be promising.
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