In previous entries we have already referred to what the current regulations on administrative procedure, specifically, article 32 of Law 39/2015, of October 1, 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 have made the normal operation of the system or the corresponding application impossible.

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 downfall of the electronic headquarters, specifying, among others, how to register; if it is necessary to inform on social networks; what to do in case someone comes to carry out a registration, etc.

Legal context

Law 39/2015

Article 32. Extension.

"1. The Administration, unless prescribed otherwise, may ex officio or at the request of the interested parties grant an extension of the established terms that does not exceed half of them, if the circumstances so advise and third party rights are not thereby prejudiced. 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 occur, in any case, before the expiration of the term in question. In no case can an already expired term be subject to extension. Agreements on extension of terms or on their denial are not subject to appeal, without prejudice to the proceeding against the resolution that puts an end to the procedure.

4. When a technical incident has made the normal operation of the system or the corresponding application impossible, and until the problem is solved, the Administration can determine an extension of the unexpired terms, and must publish on its electronic headquarters both the technical incidence that has become the concrete extension of the unexpired term."

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