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Recurso de reposición (administrative appeal) before the AEPD (Spanish Data Protection Agency) (LO 3/2018 + Ley 39/2015)

Recurso de reposición (administrative appeal) before the AEPD (Spanish Data Protection Agency) (LO 3/2018 + Ley 39/2015) is filed with AEPD (sede electrónica). 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 demanda (claim) for you. Estimated total cost: €29 to €29. Official tasa (government fee): No tasa (official fee). The recurso de reposición before the AEPD carries no fee at all.

We draft and file with the AEPD (Spanish Data Protection Agency) the optional recurso de reposición (administrative appeal), which must be lodged within 1 month, against a decision of the Agency: the shelving of your complaint, a penalty imposed on you as data controller or processor, an interim measure, or a decision on international case pooling. We also cover the correction of clerical errors (art. 109 Ley 39/2015). It includes a request to suspend enforcement of the contested decision (art. 117 Ley 39/2015) and notice of the early-payment reduction of 20% (LO 3/2018 art. 85). This is an administrative procedure: no abogado or procurador is needed. If you later decided to go to the contencioso-administrativo (administrative court) route before the Audiencia Nacional, that is a court procedure which requires a procurador and is not included in this service.

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Estimated total cost
€29 to €29
Managora's fee
€35.09 (21% VAT incl.)
Tasa (official government fee)
No tasa (official fee). The recurso de reposición before the AEPD carries no fee at all. (suplido: paid to the authority on your behalf, no VAT)
Processing time
One month from the day after the decision is notified to you. The AEPD then has one month to decide; if that deadline passes with no reply, the appeal is treated as rejected by silencio administrativo (deemed refusal by administrative silence).
Where it is filed
AEPD (sede electrónica) ↗
What you receive
Demanda (court claim)

Cost breakdown: Our fee 29 euros. The recurso de reposición before the AEPD has no tasa (official fee), so there is no additional official cost. The total cost is fixed..

Recurso de reposición (administrative appeal) before the AEPD (Spanish Data Protection Agency) (LO 3/2018 + Ley 39/2015): how is it filed?

  1. 1Answer the questions (around 10 minutes).
  2. 2Pay 29 €.
  3. 3We draft the appeal and file it with the AEPD on your behalf.
  4. 4We email you the appeal as filed along with the filing receipt.

Which documents do you need?

  • •The AEPD decision and proof that it was notified to you.
  • •Documents from the AEPD case file (complaint, written submissions (alegaciones), proposed decision).
  • •Any evidence or documents supporting your appeal.

Legal basis and things to bear in mind

  • Legal framework: LO 3/2018 + Ley 39/2015 (arts. 109, 117 and 123-124) + GDPR.
  • The recurso de reposición is optional, not compulsory: you may lodge it, or go straight on, before exhausting the administrative route.
  • This is an administrative step before the AEPD: no abogado or procurador is required.
  • If the AEPD rejects the appeal, you may go to the contencioso-administrativo (administrative court) route before the Audiencia Nacional within 2 months. That is a court procedure, it requires a procurador and it is NOT included in this service.
  • Voluntary early payment of the penalty: a reduction of 20% (LO 3/2018 art. 85).
  • Natural next steps: reclamacion_aepd, denuncia_aepd_brecha_seguridad.

Recurso de reposición (administrative appeal) before the AEPD (Spanish Data Protection Agency) (LO 3/2018 + Ley 39/2015): frequently asked questions

Recurso de reposición (administrative appeal) before the AEPD (Spanish Data Protection Agency) (LO 3/2018 + Ley 39/2015): how much does it cost?

The estimated total cost (our fee + official tasas and taxes) is €29 to €29: Our fee 29 euros. The recurso de reposición before the AEPD has no tasa (official fee), so there is no additional official cost. The total cost is fixed.. Managora's fee is €35.09, 21% VAT included (€29.00 net + €6.09 VAT). The official tasa charged by the authority (a suplido paid on your behalf, no VAT) is: No tasa (official fee). The recurso de reposición before the AEPD carries no fee at all..

Recurso de reposición (administrative appeal) before the AEPD (Spanish Data Protection Agency) (LO 3/2018 + Ley 39/2015): how long does it take?

One month from the day after the decision is notified to you. The AEPD then has one month to decide; if that deadline passes with no reply, the appeal is treated as rejected by silencio administrativo (deemed refusal by administrative silence).

Recurso de reposición (administrative appeal) before the AEPD (Spanish Data Protection Agency) (LO 3/2018 + Ley 39/2015): which documents do I need?

You need to have to hand: The AEPD decision and proof that it was notified to you., Documents from the AEPD case file (complaint, written submissions (alegaciones), proposed decision)., Any evidence or documents supporting your appeal.. 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 AEPD (sede electrónica). 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: AEPD (sede electrónica) ↗.

Shall we get started with «Recurso de reposición (administrative appeal) before the AEPD (Spanish Data Protection Agency) (LO 3/2018 + Ley 39/2015)»?

We file it for you, from start to finish.

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