Each Public Administration (PA) must have a general electronic register for the presentation and receipt of documents.
In addition, this registry must be fully interoperable with the registries of other APs to ensure IT compatibility and interconnection, and also the electronic transmission of registration entries and documents submitted to any of the registries.
Interested persons can present the documents they address to the bodies of the
- Public administrations, among others, before:
- The electronic record of the receiving PA
- The rest of the electronic records of any other AP or institutional public sector, i
- The assistance offices in matters of records.
Current regulations require that the registration assistance offices (OAMR) receive documents addressed to any public administration.
Consequently, within the framework of interoperable registers, the submission of requests will produce, on the one hand, an entry register in the receiving PA (which does not necessarily have to be the Administration to which the letter is addressed ) and on the other, a new entry in the register of the recipient PA (or Administration competent to resolve), once the document has been transferred electronically.
This circumstance can generate several legal-organizational issues that are set out in the following FAQ.
When a PA initially registers a request addressed to another Administration, a common question may be determining which of the two settlements is taken into account for the purposes of calculating deadlines.
The regulations indicate that the start of the calculation of the deadlines is determined by the date and time of submission to the electronic register of each AP or body, it is understood that it is the date of entry into the register of the competent Administration to resolve.
The date of entry into the electronic record is also relevant because it determines the maximum term for resolving administrative procedures: when they are initiated at the request of the person concerned, the terms will start to count from the date on which the request has entered in the electronic register of the competent Administration for its processing.
In any case, this effective date and time of the beginning of the calculation of terms and the maximum term of resolution must be communicated to the person concerned or his representative.
Therefore, the date that must be taken into account for the purposes of calculating deadlines in inter-administrative records is the date of entry in the administration of destination, that is, in the Administration competent to resolve.
As we have indicated, when an interested person submits documentation addressed to another Administration, the documentation must be forwarded to that AP.
The submission of the documentation must be done through the enabled digital platforms, which vary depending on the AP to which the documentation is addressed. There are three assumptions:
- Documents addressed to AP de Catalunya: sending from EACAT, through specific consignments (if any) or a generic consignment.
- Documents addressed to APs of the State outside of Catalonia: sending from the Register Interconnection System (SIR), which is accessible from EACAT. SIR is an infrastructure of the General Administration of the State that allows the exchange of electronic registration seats between Public Administrations (it is not used for notification).
- Documents addressed to the rest of APs, not users of the previous platforms: a good practice would be to send the documentation by official post and at the same time deliver it by electronic means (electronic notification, email, fax, etc.) or any other channel depending on the information we have.
Through this service we will be able to send and accept or reject the records received from other APs outside Catalonia. The service for exchanging records with non-Catalan Public Administrations is the SIR transmission service of EACAT whose purpose is to register telematic communications originating or destined for non-Catalan Public Administrations.
In order to access these services, the Catalan Public Administrations do not need to go through any registration process, you only need to be a member of EACAT and have been notified by AOC that the service has already been activated.
The activation in SIR depends on the General Administration of the State and is done in stages. From AOC, the bodies will be informed through a communication through the EACAT register.
Currently, it is not usual for PAs to send documentation on paper, among other reasons, because the Administrations comply with the principle of electronic relationship between them provided for in the regulations.
If, for whatever reason, you receive paper documentation from another Administration, that Administration should be suggested to correct this deficiency, while urging it to resend the documentation in electronic format. You can also be informed that in EACAT you will find the instructions (general and specific) to send this documentation or inform about the channel through which the documentation must be sent.
The possibility that the registration assistance offices can register any type of request or document intended for the rest of the Administrations means that transmissions between them have become de facto free.
Prior to the current regulations, if a PA did not have an agreement to record documentation addressed to another PA, the most agile option for citizens to present it (as long as it was not possible to present it in person or electronically) , it was through sending by administrative mail.
This last option has a cost that the interested party can save with the current regulation because it has free alternatives: present it at the entry register of any AP, whether or not it is the recipient of the documentation. Otherwise, the PA can send it by EACAT or SIR.
Despite being free for citizens, from the political and organizational side, the modification of the Fiscal Ordinances can be valued to include a fee that taxes the work done by the OAMRs in relation to the volume of inter-administrative shipments to which the office may have to deal with: digitization and copying of the documentation, control and tracking of the shipment to the receiving AP, etc.
Law 39/2015: art. 16, 21 and 31
Law 40/2015: art.3, 44 and 155
RD 203/2021: art. 60