Delays

1. What will happen to the computation of time limits for administrative procedures during the state of alarm?

Terms and time limits for processing procedures of public sector entities are suspended, unless they involve the exceptions set out in Royal Decree 463/2020 of 14 March, which declared the state of alarm.
The computation of time limits shall be resumed when validity of the aforementioned royal decree or, if applicable, the extensions thereof, ends.

2. What will happen to the computation of time limits for procedures relating to Social Security benefits during the state of alarm?

  • Terms and time limits for processing procedures relating to Social Security benefits are suspended.
  • The computation of time limits shall be resumed when validity of the aforementioned royal decree or, if applicable, the extensions thereof, ends.

3. Which Social Security General Treasury time limits are affected by the declaration of the state of alarm?

Only time limits related to the procedure for collection of Social Security payments are suspended. The Social Security General Treasury shall not be able to issue the following acts:

  • Debt claims
  • Enforcement orders
  • Attachment proceedings
  • Any  other procedure, whether voluntary or mandatory,  except for strictly necessary measures that may be taken by the Social Security General Treasury during processing in order to avoid serious harm to the party concerned, provided that the party concerned expresses their agreement, or when the party concerned agrees to the time limit not being suspended.

4. Which obligations must companies and workers continue to fulfil, as they are not affected by the suspension of time limits?

As Social Security procedures related to affiliation, settlements and contributions are not affected by the suspension of time limits, the following obligations are maintained for companies and workers:

  • Company registration.
  • Affiliation to the Social Security system.
  • Registration, deregistration and changes of details of companies and workers.
  • Settlement and contribution of payments and joint collection concepts.
  • Payment of contributions within the regulatory period.

5. How does the suspension of time limits affect the return of undue payments?

Returns of undue payments shall continue to be resolved as usual, except those which require statements from the applicants in order to be processed.

6. Is it necessary to request the suspension of time limits or will it be applied automatically?

No request is necessary since the suspension of time limits is automatically applied pursuant to Royal Decree 463/2020 of 14 March.

7. Who is affected by the obligation to pay contributions?

The obligation affects companies, self-employed workers and domestic employers/ employees, who must pay said contributions within the time limits established under each scheme.

8. What happens if monthly contributions are not paid?

In the event that contributions are not paid within established time limits, the corresponding surcharge would apply. However, notification of the debt claim will not occur until the suspension of time limits, as a result of the declaration of the state of alarm, has ended.

9. What will happen to vessels that are not eligible for extensions of the validity period of the certificate of revision for the mandatory on-board first aid kits, as set out in the ISM Resolution of 21 April 2020?

Shipowners may apply for the certification of revision of the mandatory on-board first aid kits by submitting the corresponding request for Revision of on-board first aid kits (REM) via the Electronic Register of the Social Security Electronic Office.

Its processing will be done on a telematic basis and will not be affected by the suspension of the administrative deadlines for the processing of procedures established in Royal Decree 463/2020, of 14 March, bearing in mind that its continuation and resolution is indispensable for the operation of the companies of the maritime-fishing sector, considered as an essential service during the state of emergency.


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