From 15 January 2026, tax appeals<\/strong> before the economic-administrative courts are governed by a new regulation that strengthens the mandatory use of electronic means for companies and professionals. The regulation introduces standardised electronic forms, formalises online submission of documents and reinforces electronic notifications<\/strong>. For businesses, this requires reviewing digital certificates, notification systems, and deadline controls to avoid procedural issues.<\/p>\n<\/div><\/div><\/div><\/div><\/div> The digitalisation of tax procedures takes a decisive step forward in 2026. From 15 January, a specific regulation on electronic actions in economic-administrative tax appeals<\/strong> comes into force, directly affecting companies, professional firms and tax representatives.<\/p>\n This regulation replaces the framework in force since 2009 and adapts appeal procedures to the current digital environment, in line with Law 39\/2015<\/strong> and the established practice of electronic interaction with the Spanish Tax Agency<\/strong> and the economic-administrative courts<\/strong>.<\/p>\n<\/div> The new framework is approved by Order HAC\/1361\/2025<\/strong>, published in the Official State Gazette (BOE)<\/strong>, and applies to all actions before the economic-administrative courts from 15 January 2026 onward.<\/p>\n The order specifically regulates the use of electronic means in economic-administrative proceedings and builds on the general principles established in Law 39\/2015<\/strong>.<\/p>\n<\/div> The obligation to interact electronically applies in particular to: For these parties, paper submissions are no longer valid and may lead to requests for correction or procedural risks related to deadlines.<\/p>\n<\/div> The main change is not only digitalisation itself, but\u00a0also the formal regulation of\u00a0how electronic actions must be carried out<\/strong><\/span>.<\/p>\n<\/div> Companies and professionals subject to the obligation must submit electronically: Using an incorrect submission channel may have significant procedural consequences.<\/p>\n<\/div> The order approves 16 official electronic forms<\/strong>, replacing the three models previously in use.<\/p>\n These forms cover nearly all possible actions in the procedure and serve as the standard channel of communication with the economic-administrative courts.<\/p>\n Their purpose is to: The regulation reinforces the use of: Proper management of representation is essential, as all actions are carried out in a wholly digital environment.<\/p>\n<\/div> Notifications are issued electronically, with legal effects triggered by their availability in the electronic mailbox.<\/p>\n This requires companies to: Lack of awareness of a notification does not prevent its legal effects.<\/p>\n<\/div> From a substantive perspective, the regulation does not restrict the right to appeal. However, it significantly increases formal and organisational requirements<\/strong>.<\/p>\n<\/div> The main risks include: In many cases, the issue lies not in the merits of the appeal but in procedural compliance.<\/p>\n<\/div> What to review in your company regarding electronic tax appeals in 2026<\/strong><\/p>\n \u2022 Digital certificates and electronic identification systems. The new regulation does not alter the right to appeal, but it does redefine how that right must be exercised. In 2026, tax appeals<\/strong> are fully electronic and require organisation, control and specialised advice to avoid unnecessary procedural risks.<\/p>\n<\/div>Electronic tax appeals in 2026: regulatory context and scope of the change<\/strong><\/h2><\/div>
Which regulation governs electronic tax appeals and who is affected<\/strong><\/h2><\/div>
Order HAC\/1361\/2025 and entry into force on 15 January 2026<\/strong><\/h3><\/div>
Parties required to use electronic means in tax appeal proceedings<\/strong><\/h3><\/div>
\u2022 Legal entities.
\u2022 Entities without legal personality.
\u2022 Regulated professionals acting as representatives.
\u2022 Tax representatives of taxpayers.<\/p>\nKey changes in economic-administrative tax appeals from 2026<\/strong><\/h2><\/div>
Mandatory use of electronic means in tax appeals<\/strong><\/h3><\/div>
\u2022 Economic-administrative appeals.
\u2022 Appeals for annulment and review.
\u2022 Statements and pleadings.
\u2022 Applications for suspension.
\u2022 Responses to requests and corrections.<\/p>\nOfficial electronic forms for economic-administrative appeals<\/strong><\/h3><\/div>
\u2022 Reduce formal errors.
\u2022 Facilitate internal processing.
\u2022 Harmonise criteria across different courts.<\/p>\n<\/div>Electronic identification, signature and representation in tax procedures<\/strong><\/h3><\/div>
\u2022 Qualified electronic certificates.
\u2022 The Cl@ve<\/strong> system, where applicable.
\u2022 Secure verification codes.
\u2022 Electronic seals in notifications and decisions.<\/p>\nElectronic notifications and deadline control in tax appeals<\/strong><\/h3><\/div>
\u2022 Actively monitor electronic notification systems.
\u2022 Clearly assign internal responsibility.
\u2022 Avoid delayed or missed access.<\/p>\nImpact of the new electronic tax appeal regulation on companies and SMEs<\/strong><\/h2><\/div>
Formal risks in electronic tax appeal procedures<\/strong><\/h3><\/div>
\u2022 Incorrect use of electronic forms.
\u2022 Expired or invalid digital certificates.
\u2022 Improperly registered powers of attorney.
\u2022 Insufficient control of electronic notifications.<\/p>\nKey changes in tax appeals: summary table<\/strong><\/h2><\/div>\n
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\n \nAspect<\/th>\n Before 2026<\/th>\n From 15 January 2026<\/th>\n<\/tr>\n<\/thead>\n \n Submission<\/td>\n Mixed and less regulated<\/td>\n Fully electronic and formalised<\/td>\n<\/tr>\n \n Forms<\/td>\n 3 models<\/td>\n 16 official electronic forms<\/td>\n<\/tr>\n \n Company interaction<\/td>\n Electronic in practice<\/td>\n Electronically mandatory<\/td>\n<\/tr>\n \n Notifications<\/td>\n Electronic, fragmented<\/td>\n Reinforced and regulated system<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n<\/div>\n
\n\u2022 Powers of attorney and representation before the economic-administrative courts.
\n\u2022 Electronic notification management and deadline control.
\n\u2022 Coordination with your tax and legal advisor in economic-administrative proceedings.<\/p>\n<\/div><\/div><\/div>In 2026, tax appeals are electronic or they are not<\/strong><\/h2><\/div>