Article 16 of Law 39/2015, of 1 October, on the common administrative procedure of public administrations (LPACAP) determines that all public administrations (AAPP) must have a general electronic register, where s 'submit all documents submitted to the administrative bodies, public bodies or entities linked to or dependent on them.

In the same sense, according to the LPACAP, the AAPP must provide model forms for interested parties to process their applications, prior communications, etc.

It follows from this regulation that interested parties can go to the electronic register of any public administration, since it must be interoperable and be interconnected with the electronic register of the rest of AAPP.

Local bodies currently have the AOC's ERES service at their disposal, for which they can comply with this obligation. They can also use the eTRAM service, where they will find a generic instance to make requests.

On the other hand, in the event of a technical incident that prevents the normal operation of the applications and, ultimately, the submission of applications from interested parties, Article 32.4 of the LPACAP allows AAPPs to extend the deadlines.

In this regard, as suggested in the shadow regarding the action in the face of technical incidents that affect compliance with deadlines, it is highly recommended to develop internal protocols by which to establish a response mechanism in cases such as the one raised.

Notwithstanding the above, it is true that there is the Seventh Final Provision which postpones until October 2018 the entry into force of the provisions on records, but it must be understood that it is a period of maximum , so that if a company, for example, goes to the electronic register of any AAPP and makes an electronic application that goes to an entity that does not have an electronic register, the recipient must forward it, by the means at its disposal, to the receiving entity.

Legal Context

Law 39/2015

Article 16. Records .

"1. Each Administration must have a general electronic register, in which all documents submitted or received by any administrative body, public body or entity linked to or dependent on them must be recorded. It may also be recorded. the release of official documents addressed to other bodies or individuals [...]

The general electronic register of each Administration must function as a portal that facilitates access to the electronic registers of each body. Both the general electronic register of each Administration and the electronic registers of each body must comply with the guarantees and security measures provided for in the legislation on the protection of personal data.


4. The documents that the interested parties address to the organs of the public administrations can be presented:

a) In the electronic register of the Administration or body to which they are addressed, as well as in the other electronic registers of any of the subjects referred to in article 2.1.

b) At post offices, as established by regulations. c) At Spanish diplomatic representations or consular offices abroad.

d) At the registration assistance offices.

e) In any other that establishes the valid dispositions.

The electronic records of each and every administration must be fully interoperable, so that computer and interconnection compatibility is guaranteed, as well as the telematic transmission of the registry entries and documents presented in any of the records. ”

Article 32. Extension.

“4. When a technical incident has prevented the normal operation of the system or the corresponding application, and until the problem is resolved, the Administration may determine an extension of the deadlines, and must publish in the electronic office both the incident technique that has become the concrete extension of the unexpired term. ”

Article 66. Initiation applications.

“6. When the Administration, in a specific procedure, expressly establishes specific models for the submission of applications, these are of obligatory use by the interested parties. ”

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