Objection to a mining research permit or mining concession

Objection to a mining research permit or mining concession is filed with Órgano minero de la comunidad autónoma donde está el recurso (o el MITECO, si está en terrenos de dos o más comunidades autónomas o en la plataforma continental). With Managora you do it 100% online: you answer a few questions, sign a digital mandato (power of representation) and we draft, sign and file your recurso (appeal) for you. What we charge you: €399. Official tasa (government fee): No official fees. Making representations or objecting during the public consultation of a mining research permit or a mining concession carries no fee: the price of 399 € (VAT included) is all you pay.

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Our lawyer drafts and lodges your objection (alegaciones or oposición) to a permiso de investigación (mining research permit) or a concesión de explotación (mining concession) during its public consultation, which lasts only 15 days from publication of the notice in the BOE. We review the notice, the project and the restoration plan, identify the grounds (land that is not free and registrable, earlier mining rights, environmental assessment, restoration and financial guarantees) and lodge it on your behalf, under your authorisation, with the mining authority of the autonomous community, or with the MITECO if the resource lies in two or more communities. We give you the document and the proof of filing.

Practical guide: Mining Investigation Permits and Exploitation Concessions in Spain: Sections A to D, Deadlines, Fees, Restoration and Strategic Projects (Rare Earths, Lithium, Tungsten). Requirements, deadlines and the steps, explained.

What we charge you: €399
Managora's fee: €399.00 (21% VAT incl.)
Tasa (official government fee): No official fees. Making representations or objecting during the public consultation of a mining research permit or a mining concession carries no fee: the price of 399 € (VAT included) is all you pay.
Processing time: 15 working days (Saturdays, Sundays and public holidays do not count) from publication of the notice in the BOE: after that, no objection at all is admitted. If the project needs an environmental impact assessment, its public consultation lasts at least 30 working days, and the one for the restoration plan no less than 30 days (when there is an environmental assessment, it is the same one). We prepare and lodge the document within whichever period is still open; the decision is taken by the mining authority when it rules on the file.
Where it is filed: Órgano minero de la comunidad autónoma donde está el recurso (o el MITECO, si está en terrenos de dos o más comunidades autónomas o en la plataforma continental) ↗
What you receive: Recurso (administrative appeal)

Cost breakdown: Objection to a mining permit 399 € (VAT included) for one interested party's objection to a mining research permit or a mining concession, lodged on your behalf. No official fees: making representations in the public consultation is free..

Objection to a mining research permit or mining concession: how is it filed?

1Answer the questions (around 10 minutes) and upload the notice and proof of your interest.
2If the period for objections has already ended or has not opened yet, we tell you before you pay.
3Payment: 399 € (VAT included). No official fees.
4Sign on screen the authorisation for us to lodge the objection on your behalf. We never ask for your digital certificate. If the mining authority requires another form of proof of representation, we tell you the same day.
5We review the file on public display (the research or extraction project, the restoration plan and the environmental documents) and compare the permit area with your land, your mining right or your municipality.
6Our lawyer drafts the document with the grounds and we send it to you to read before it is lodged.
7We lodge it with the mining authority's electronic register within the deadline and send you the proof of filing. Forward us any notification you receive about the file.

Which documents do you need?

•The public consultation notice (BOE, provincial gazette or town hall edict).
•If you are a landowner: the title deed, the nota simple (land registry extract) or the IBI (property tax) bill for the affected property.
•If you hold a mining right: the title of your permit or concession.
•If you are acting for an organisation: the document showing your position, if you have it to hand.
•Photos, plans, reports or studies supporting your grounds, if you have them.
•The authorisation for us to lodge the objection on your behalf: you sign it on screen at the end.

Prerequisites we also handle for you

This procedure may require documents that we also obtain. If your case needs one and you do not have it, ask us for it here and come back once you have it:

Registro de la Propiedad (Land Registry): nota simple / certification€99

Legal basis and things to bear in mind

Once an application for a mining research permit is admitted, the mining authority publishes it in the BOE and in the provincial gazette, and interested parties have 15 days from publication in the BOE to object; after that, no objection at all is admitted. A direct mining concession is processed in the same way as a research permit, and every concession file goes through public consultation.
Grounds the law gives you: research permits and direct concessions are only granted over land that is free and registrable (francos y registrables), and there can be no more than one mining concession over the same land; the application must include a project with a work programme, an investment budget and a financial study, and without an authorised restoration plan neither the permit nor the concession can be granted.
The restoration plan is submitted with the application, is signed by a qualified technical expert, is authorised at the same time as the mining title and goes through a public consultation of at least 30 days. Once the title is granted, work cannot start until the financial guarantees are in place.
An ordinary environmental impact assessment is needed, among others, for open-pit mines affecting more than 25 ha or moving more than 200.000 m³ of earth a year and for those extracting substances that generate acidity or toxicity; research projects with a pilot face, galleries or a mining waste facility go to the simplified assessment. The public consultation of the ordinary assessment lasts at least 30 working days and is another opportunity to make representations.
The decision is taken by the mining authority of the autonomous community where the resource lies; if it lies in two or more autonomous communities or on the continental shelf, the MITECO decides.
If the project is a strategic project under the EU Critical Raw Materials Act, it is deemed to be in the public interest and may be considered of overriding public interest against the protection of habitats, waters and birds; its permit-granting process cannot exceed 27 months where it involves extraction. That recognition does not exempt it from the other authorisations and leaves the public's participation rights intact. The declaration of Proyecto Estratégico de Inversión under Real Decreto 731/2026 is a separate one, applied for by the promoter in Spain.
The decision lies with the mining authority: we cannot guarantee that it will uphold the objection. If it rejects it and grants the permit or concession, we tell you which appeal is available and its deadline; the Managora law firm handles it as a separate engagement, quoted in advance.

Objection to a mining research permit or mining concession: frequently asked questions

Objection to a mining research permit or mining concession: how much does it cost?

We charge you €399: our fee plus, where applicable, the fixed official tasa we advance. Objection to a mining permit 399 € (VAT included) for one interested party's objection to a mining research permit or a mining concession, lodged on your behalf. No official fees: making representations in the public consultation is free.. Managora's fee is €399.00, 21% VAT included (€329.75 net + €69.25 VAT). The official tasa charged by the authority (a suplido paid on your behalf, no VAT) is: No official fees. Making representations or objecting during the public consultation of a mining research permit or a mining concession carries no fee: the price of 399 € (VAT included) is all you pay..

Objection to a mining research permit or mining concession: how long does it take?

15 working days (Saturdays, Sundays and public holidays do not count) from publication of the notice in the BOE: after that, no objection at all is admitted. If the project needs an environmental impact assessment, its public consultation lasts at least 30 working days, and the one for the restoration plan no less than 30 days (when there is an environmental assessment, it is the same one). We prepare and lodge the document within whichever period is still open; the decision is taken by the mining authority when it rules on the file.

Objection to a mining research permit or mining concession: which documents do I need?

You need to have to hand: The public consultation notice (BOE, provincial gazette or town hall edict)., If you are a landowner: the title deed, the nota simple (land registry extract) or the IBI (property tax) bill for the affected property., If you hold a mining right: the title of your permit or concession., If you are acting for an organisation: the document showing your position, if you have it to hand., Photos, plans, reports or studies supporting your grounds, if you have them., The authorisation for us to lodge the objection on your behalf: you sign it on screen at the end.. You do not upload them here: we collect the details through the guided chat.

Who files the procedure?

Managora files it in your name with Órgano minero de la comunidad autónoma donde está el recurso (o el MITECO, si está en terrenos de dos o más comunidades autónomas o en la plataforma continental). You only provide the details through the chat and sign a mandato (power of representation); we prepare, sign and register it.

Can it be done online?

Yes. The whole process is online: you answer a few questions in the guided chat, sign a simple mandato on screen and receive the receipt and the official documents by email, with full legal validity.

Related procedures

Based on the legislation in force and on the official site of the competent authority: Órgano minero de la comunidad autónoma donde está el recurso (o el MITECO, si está en terrenos de dos o más comunidades autónomas o en la plataforma continental) ↗.

Managora Gestion SL (company number B88823893) is a private company. We are not Órgano minero de la comunidad autónoma donde está el recurso (o el MITECO, si está en terrenos de dos o más comunidades autónomas o en la plataforma continental), we are not affiliated with, authorised or endorsed by any public authority, and this website is not an official government portal. What you pay on this page is our fee for preparing, signing and filing the procedure on your behalf: it is separate from the official tasa, which where applicable belongs to the authority and is shown to you separately. You can carry out this procedure yourself, directly with Órgano minero de la comunidad autónoma donde está el recurso (o el MITECO, si está en terrenos de dos o más comunidades autónomas o en la plataforma continental).

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