Who must receive electronic notifications in Spain?

In Spain, all companies and other legal entities must receive official notifications electronically, along with entities without legal personality, members of regulated professions acting in that capacity, people representing any of these, and public employees in their work dealings. Private individuals can usually choose between paper and electronic, but there are important exceptions: the Agencia Tributaria runs its own compulsory scheme that can include some individuals, and self-employed people (autónomos) must receive Seguridad Social notifications electronically. Anyone in these groups who does not check their electronic mailbox risks the 10-day rule.

The general rule: article 14 of Ley 39/2015

Ley 39/2015 sets the default rules for dealing with Spanish public administrations. Article 14.1 says that personas físicas (individuals) can choose at any time whether to deal with the administration electronically or not, and can change that choice later.

Article 14.2 then lists who is obliged to deal with the administration electronically "for any step of an administrative procedure". At minimum this covers:

1. Personas jurídicas (legal entities), such as a sociedad limitada (SL), a sociedad anónima (SA), associations and foundations.
2. Entidades sin personalidad jurídica (entities without legal personality), such as a comunidad de bienes.
3. People carrying out a professional activity that requires colegiación obligatoria (compulsory membership of a professional association), for procedures connected with that activity. The law names notaries and property and commercial registrars, but it also covers, for example, lawyers and architects.
4. Anyone who represents someone in the groups above. A gestor filing on behalf of an SL must do so electronically.
5. Public employees, for dealings related to their employment.

Article 41.1 applies the same logic to notifications. If you are obliged to deal electronically, notifications to you will be electronic. If you are not, you can opt in or out using the body's forms.

Article 14.3 also lets each administration extend the obligation by regulation to specific groups of individuals who can be shown to have access to the technology, for example because of their profession. This is why some procedures, such as certain grant applications or public sector job applications, are electronic only.

What "obliged" means in practice

Being obliged means you cannot insist on paper. The body will place notifications in its sede electrónica, in the DEHú, or both (see our DEHú guide), and you have 10 calendar days to open each one before it is treated as rejected.

If a body has no electronic contact details for an obliged person, Real Decreto 203/2021 says the first notification in a procedure it starts should go on paper, warning that the following ones will be electronic. After that, everything is electronic.

Owning a Spanish company from abroad does not change any of this. An SL owned by a UK resident is still a Spanish legal entity and is fully obliged. The company's registered and tax addresses are a separate question, covered in domicilio social vs domicilio fiscal.

The Agencia Tributaria's own scheme (NEO)

The tax agency had a compulsory electronic notification scheme before Ley 39/2015. It is set out in Real Decreto 1363/2010 and is usually called NEO (notificaciones electrónicas obligatorias). It still applies alongside the general law.

Article 4.1 of the decree includes, by the first letter of the tax number (NIF):

NIF starts with	Type of entity
A	Sociedad anónima
B	Sociedad limitada
N	Foreign entities without Spanish nationality
W	Permanent establishments and branches of non-resident entities
U	Temporary joint ventures (UTE)
V	Certain funds and economic interest groupings

Article 4.2 then includes anyone, whatever their legal form, who:

• is on the large companies register (grandes empresas)
• has opted for corporate tax group consolidation, or the VAT group regime
• is registered for monthly VAT refunds (REDEME)
• acts as a customs representative or files customs declarations electronically

This second list is how individuals, including autónomos, can end up in NEO. Signing up to the monthly VAT refund register, for example, brings you into the scheme even if you are a sole trader.

Under article 5 of the decree, the Agencia Tributaria must notify each person of their inclusion, normally on paper. Once included, you stay in until the circumstances end and you ask to be excluded.

Individuals who are not obliged can also join voluntarily through the tax agency's sede electrónica, and can cancel a voluntary subscription later. While you are in the scheme, voluntarily or not, the 10-day rule applies.

Autónomos and the Seguridad Social

Self-employed people have a stricter position with the Seguridad Social than with the tax agency.

Since 1 October 2018, autónomos in the RETA (the special scheme for self-employed workers) must deal with the Tesorería General de la Seguridad Social (TGSS) electronically, either through the Sistema RED (usually via a gestoría authorised in RED) or directly on the Seguridad Social's sede electrónica. This comes from Orden ESS/484/2013, as amended by Orden ESS/214/2018.

Orden ESS/485/2013 then makes everyone who must be in the Sistema RED receive Seguridad Social notifications electronically, by logging in to the sede. Notifications are placed both with the autónomo and with the RED-authorised person handling their account, and a notification not opened within 10 calendar days is treated as rejected.

Some groups are excluded from the RED obligation, for example employers registered only for household staff, and certain self-employed fishing workers.

So a British autónomo living in Spain, even one who has never opted into anything with Hacienda, is already in a compulsory electronic system for Seguridad Social debts, payment demands and decisions.

Other bodies with their own rules

A few bodies have specific regimes:

• The DGT notifies traffic fines through its Dirección Electrónica Vial (DEV). Companies that own or lease vehicles are expected to use it. See DGT fines.
• Regional governments and town halls apply article 14 but may extend the obligation for particular procedures, and some use their own notification platforms.

If you are not sure whether a body treats you as obliged, look at how it has been contacting you. A paper letter warning that future notifications will be electronic is a clear sign.

Private individuals: the choice and its risks

A homeowner, retiree or employee who is not in any of the groups above can stay on paper with most bodies. Paper notifications go to your Spanish address on file, with up to two delivery attempts, and if those fail they can be published in the BOE (the official gazette), at which point they can take effect without you ever seeing them.

Choosing electronic notification can be safer if you live abroad, as long as someone checks it every few days. Choosing it and then not checking is the worst of both. Either way, the address the administration holds for you matters.

How Hola Post helps

Hola Post gives you a staffed Spanish address in Almería, Spain for paper post, scanned the same day, and can also be registered as your representative to collect electronic notifications from the AEAT, the Seguridad Social, the DGT, the DEHú and other sedes every working day. Each item appears in your inbox with an English summary and the deadline. See Spanish notifications, services for businesses, or start here.

Frequently asked questions

Does a Spanish SL have to receive notifications electronically?

Yes. Every legal entity, including a sociedad limitada (SL), is obliged to deal with Spanish public administrations electronically under article 14.2 of Ley 39/2015, and SLs are also expressly included in the Agencia Tributaria's compulsory electronic notification scheme.

Can a private individual in Spain choose paper notifications?

Generally yes. Article 14.1 of Ley 39/2015 lets individuals choose electronic or paper and change their choice at any time, unless a specific rule obliges them to use electronic means for a particular procedure.

Do autónomos have to receive electronic notifications?

For the Seguridad Social, yes. Self-employed people registered in the RETA must use the Sistema RED or the Seguridad Social's sede electrónica and receive notifications there. For the Agencia Tributaria, an autónomo is not included automatically just for being self-employed, but can be included in certain situations, such as being registered for monthly VAT refunds.

What is NEO at the Agencia Tributaria?

NEO stands for notificaciones electrónicas obligatorias, the tax agency's compulsory electronic notification scheme under Real Decreto 1363/2010. It covers companies and certain other taxpayers, and the agency tells each one, normally by post, when they have been included.

If I'm obliged to receive electronic notifications and don't check, what happens?

Each notification you don't open is treated as rejected after 10 calendar days, and the procedure continues. Deadlines to pay or appeal then run without you having read anything.

Sources

• Ley 39/2015, de 1 de octubre, arts. 14 and 41 (BOE)
• Real Decreto 1363/2010, de 29 de octubre (BOE)
• Orden ESS/485/2013, notificaciones electrónicas en la Seguridad Social (BOE)
• Orden ESS/484/2013, Sistema RED (BOE)

This guide is general information, not legal or tax advice. Rules change, so check your own situation with a gestor, accountant or lawyer.