Law 39/2015 , of 1 October, on the common administrative procedure of public administrations (LPACAP), provides for different options for which interested parties can send the documents they must submit to the register of other administrations. public. In particular, Article 16.4 (b) and (d) provides that they may be addressed, inter alia, to post offices and registrar assistance offices.

The possibility that the registration assistance offices, without the need to sign agreements between them, may receive any type of request or document that must be sent to the rest of the Administrations means that the remittances between them have become de facto, free. That is to say, prior to the LPACAP when an Administration did not have an agreement to receive documentation addressed to another Administration, the most agile option for the citizen to present it (as long as the face-to-face presentation was not feasible or electronic), was through mailing. This last shipping option has a cost that, with the new regulation, the interested party is not obliged to assume.

The registration exchange service with non-Catalan public administrations is EACAT's SIR delivery service whose purpose is to register telematic communications whose origin or destination is non-Catalan public administrations. Through this service, therefore, we can send and accept or reject the records received from other public administrations outside Catalonia.

To be able to access this service, it is not necessary for the Catalan Public Administrations to carry out any registration procedure , you only need to be a member of EACAT and have been notified by the AOC that the service has already been activated. The activation depends on the Ministry of Finance and Public Administrations and is done in stages. The AOC will inform the bodies through a communication through the EACAT register.

On the other hand, from the political point of view, it will be necessary to assess in each case, and depending on the volume and the progressive adequacy of the entities likely to receive entry records, the need to include in the Tax Ordinances a tax levied on the work carried out by the registries assistance offices in relation to the authentication of the documentation (which would be the equivalent of the certification carried out in the paper processing) and the control and monitoring of the documentation submitted.

Legal Context

Law 39/2015

Article 16. Records .

"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 their computer and interconnection compatibility is guaranteed, as well as the telematic transmission of the registry entries and of the documents presented in any of the records. [...] ”

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