first The request must be accepted.

second It is necessary to inform the interested person that he is a subject obliged to relate electronically with the Administration. To this end:

  • The registration assistance offices (OAMR) should have a model of the request for amendment due to the means used in the processing, to hand them to the interested parties obliged to process electronically.
  • It is recommended to make a request in the same act in which the in-person presentation of the request is entered in the register. Given that the request refers only to the change in processing modality, this could be carried out by the current OAMRs.
  • The requirement will warn that they must amend the application through electronic submission.
  • The request will state that, in any case, the date of submission of the application will be the date on which the amendment was made and not the date of presentation in person.

It should be borne in mind that according to Law 39/2015, of October 1, on common administrative procedure of public administrations (LPACAP), the obligation to process electronically by certain subjects entered into force on the past 2 October 2016.

However, it is advisable for the Public Administrations to set a date to make this obligation effective, taking into account the following:

  • It is necessary to incorporate in the catalog of procedures the information for the obliged subjects on how they must carry out the submission of applications and the provision of documentation, and from which date.
  • Although the regulations do not provide for it, it is advisable to establish means of assistance for those obliged subjects who state that they do not have sufficient resources, or the necessary knowledge to carry out the electronic procedures.
  • It would be convenient to hold information/awareness sessions aimed at the obliged subjects.
  • Provision must also be made for the provision of suitable technological means for the Administration staff who require it (for example, double screens for architects and engineers; programs that allow online project measurement; etc.).
  • For the effective implementation of the obligation of personnel at the service of the AAPP, it will also be necessary to foresee how to assist those groups that do not usually work with a computer (for example, city maintenance staff, nursery schools, local police, etc.).
Legal context

Law 39/2015:

Article 68. Amendment and improvement of the application.

"4. If any of the subjects referred to in article 14.2 and 14.3 present their application in person, the public administrations must require the interested party to correct it through their electronic submission. For these purposes, the date on which the amendment was carried out is considered as the date of submission of the application."

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