Each Public Administration (PA) must have a general electronic register for the presentation and receipt of documents.
In addition, this register must be fully interoperable with the registers of other PAs to guarantee IT compatibility and interconnection, as well as the electronic transmission of registry entries and documents submitted to any of the registers.
Interested persons may submit the documents addressed to the bodies of the
- Public administrations, among others, in relation to:
- The electronic record of the recipient PA
- The rest of the electronic records of any other PA or institutional public sector, and
- Registration assistance offices.
Current regulations require that registration assistance offices (OAMR) receive documents addressed to any public administration.
Consequently, within the framework of interoperable registers, the submission of applications will produce, on the one hand, an entry record in the receiving PA (which does not necessarily have to be the Administration to which the document 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 explained in the following FAQ.
When an AP initially registers a request addressed to another Administration, a common doubt may be determining which of the two entries 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 presentation in the electronic register of each AP or body, which is understood to be the date of entry in the register of the Administration competent to resolve.
The date of entry into the electronic register is also relevant because it determines the maximum period for resolving administrative procedures: when they are initiated at the request of the interested person, the periods will begin to count from the date on which the request has been entered into the electronic register of the competent Administration for its processing.
In any case, this effective date and time of the start of the calculation of deadlines and the maximum resolution period must be communicated to the interested person or their representative.
Therefore, the date that must be taken into account for the purposes of calculating deadlines in inter-administrative registers is the date of entry in the destination administration, that is, in the Administration competent to resolve.
As we have indicated, when an interested person presents documentation addressed to another Administration, the documentation must be sent to that PA.
The submission of documentation must be done through the enabled digital platforms, which vary depending on the PA to which the documentation is addressed. There are three cases:
- Documents addressed to AP de Catalunya: sent from EACAT, through specific submissions (if any) or a generic submission.
- Documents addressed to State PAs outside Catalonia: sent from the Register Interconnection System (SIR), which is accessible from EACAT. SIR is an infrastructure of the General State Administration that allows the exchange of electronic registration seats between Public Administrations (not used for notification).
- Documents addressed to other PAs, not users of the previous platforms: a good practice would be to send the documentation by 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 records received from other PAs outside Catalonia. The service for exchanging records with non-Catalan public administrations is the SIR transmission service of EACAT which aims to register telematic communications that have non-Catalan public administrations as their origin or destination.
To access these services, it is not necessary for the Catalan public administrations to carry out any registration procedures, you only need to be a member of EACAT and have been notified by AOC that the service has already been activated.
Activation in SIR depends on the General State Administration and is done in stages. AOC will inform the entities through a communication through the EACAT register.
Currently, it is not common for PAs to send documentation on paper, among other reasons, because the Administrations comply with the principle of electronic relations between them provided for in the regulations.
If, for any reason, you receive paper documentation from another Administration, you should suggest to this Administration that it corrects this deficiency, urging it to resend the documentation in electronic format. You can also be informed that in EACAT you will find the submissions (general and specific) to send this documentation or, inform the channel through which the documentation should 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 current regulations, if a PA did not have an agreement to register documentation addressed to another PA, the quickest option for citizens to submit it (provided that in-person or electronic submission was not feasible) was by sending it 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 registration of any AP, whether or not it is the recipient of the documentation. If not, the AP can send it by EACAT or SIR.
Despite the fact that it is free for citizens, from a political and organizational perspective, the modification of the Tax Ordinances may be considered to include a fee that taxes the work carried out by the OAMRs in relation to the volume of inter-administrative shipments that the office may have to deal with: digitization and copying of documentation, control and monitoring of the shipment to the recipient PA, etc.
Law 39/2015: art. 16, 21 and 31
Law 40/2015: art.3, 44 and 155
RD 203/2021: art. 60