To whom and in what time frame can the enforcement order be appealed?

Clarify your doubts by consulting your particular case


In general, acts dictated in the enforcement procedure are appealed via the same procedural channels as other acts of collection management (see Chapter 4).

Nevertheless, and in summary, there are two appeal possibilities:

a) Filing an administrative appeal prior to the economic-administrative route. It starts by sending a written letter, which should be submitted to the same body that issued the act (collection agencies), within fifteen working days, counting from the following day the notification of the administrative act for which the review is requested. For administrative purposes, Saturdays, aside from bank holidays, are classed as working days.

The resolution expresses or negative administrative silence allows the taxpayer to go to the economic-administrative.

b) Directly interposing an economic-administrative claim.
It starts by sending a written letter which should be submitted within fifteen working days, usually to the Regional Economic-Administrative Tribunal of the corresponding Autonomous Community.

Depending on the amount, the claim may be at first instance (with subsequent appeal raised before the Regional Economic-Administrative Tribunal) or in a single instance (no possibility of an appeal later raised).

The decision of the Regional Economic Administrative Tribunal, in a single instance, or the Central Administrative Economic Court, in the case of the appropriate administrative appeal, puts an end on the administrative path and opens up to the courts.

The reader can go to chapter 4 of this Manual, where the remedies that taxpayers have against administrative acts is discussed in more detail.