In previous posts we have already referred to the fact that the current regulations on administrative procedure, in particular Article 32 of Law 39/2015, of 1 October, on common administrative procedure of public administrations, provide for the possibility of extending deadlines and the duty of information in the event of technical incidents that make it impossible for the ordinary operation of the system or the corresponding application.

In this sense, it would be advisable for the Public Administrations to draw up a Contingency Plan or internal action protocol, to establish what actions are necessary in the event of a drop in the electronic headquarters, specifying, among other things, how to register; if you need to report on social media; what to do in case someone comes to register, etc.

Legal Context

Law 39/2015

Article 32. Extension.

“1. The Administration, unless otherwise provided, may grant ex officio or at the request of the interested parties an extension of the established deadlines not exceeding half of these, if the circumstances so warrant and this does not prejudice the rights of third parties. The extension agreement must be notified to the interested parties.


3. Both the request of the interested parties and the decision on the extension must take place, in any case, before the expiry of the period in question. In no case may an expired term be extended. Agreements on the extension of time limits or on their refusal are not subject to appeal, without prejudice to any proceedings against the decision terminating the proceedings.

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 shall publish in the electronic office both the technical impact that has occurred as a concrete extension of the unexpired term. ”

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