On the one hand, Law 39/2015, of 1 October, on the common administrative procedure of public administrations (LPACAP) recognizes in article 13.a) the right of persons to communicate with the administrations in relations with them through a General Electronic Access Point (PAGE) of the Administration.
The PAGE, however, is not defined by the LPACAP as it seeks to simplify and concentrate in a centralized portal all channels of communication with the public. Although Royal Decree 1671/2009, implementing Law 11/2007, contains a reference to the General Access Point, it is preached with respect to the State Administration and not to the rest of the Administrations.
On the other hand, in accordance with Law 40/2015, of 1 October, on the legal regime of the public sector (LRJSP), each Public Administration must create an electronic office for the exercise of its powers. . The LRJSP itself also determines that an internet portal must be available. None of them equals PAGE.
Indeed, according to article 38 of the LRJSP, the electronic office is the electronic address available to citizens through telecommunications networks, owned by a public administration.
And the internet portal, regulated in article 39 of the LRSJP, as the electronic point that allows access to published information.
Consequently, the planned access to the LPACAP and the LRJSP is a portal –a website– of the Administration where all the links to the different electronic offices of the Administration are listed.
From a practical point of view, and according to the Catalan interoperability model, the AOC Consortium is working to make available to the Catalan public sector a PAGE that brings together all the Catalan electronic headquarters, which in turn would be connected to the point of general access to the state.
Article 13. Rights of persons in their relations with public administrations.
“Those who, in accordance with article 3, have the capacity to act before the public administrations, are the holders, in their relations with them, of the following rights:
a) To communicate with the public administrations through an electronic general access point of the Administration. ”
Article 38. The electronic headquarters.
“1. The electronic office is the electronic address, available to citizens through telecommunications networks, the ownership of which corresponds to a Public Administration, or to one or more public bodies or entities governed by public law in the exercise of the their competencies. ”
Article 39. Internet portal.
“Internet portal means the electronic access point whose ownership corresponds to a Public Administration, public body or public law entity that allows access via the Internet to published information and, if 'appropriate, in the corresponding electronic office.'