Suspension of Terms in Administrative Procedures

The Argentine Government has ordered the suspension of all terms in ongoing administrative procedures, with some exceptions

By means of Decree No. 298/2020, issued within the context of the public health emergency established by Law No. 27,541 and broadened by Decree No. 260/2020, on the COVID-19 coronavirus pandemic, the Argentine Executive ordered:

1. To suspend all terms in ongoing administrative procedures, including both the general administrative procedures under the Administrative Procedure Act No. 19,549 as well as other special administrative procedures, from March 20 to March 31, 2020, without prejudice to the validity of the acts performed or to be performed within that period.

2. To exclude from the suspension the administrative procedures related to the public health emergency established by Law No. 27,541 and broadened by Decree No. 260/2020 and its amending and complementary rules.

3. To authorize the jurisdictions, entities and agencies that comprise the Argentine Public Sector pursuant to section 8 of the Financial Administration Law No. 24,156, within the scope of their respective powers, to provide exceptions to the general suspension of terms referred to in point 1.

Subsequently, the suspension of terms provided by Decree No. 298/2020 was extended from April 1 to April 12, 2020 by means of Decree No. 327/2020, from April 13 to April 26, 2020 by means of Decree No. 372/2020, from April 27 to May 10, 2020 by means of Decree No. 410/2020, from May 11 to May 24, 2020 by means of Decree No. 458/2020, from May 25 to June 7, 2020 by means of Decree No. 494/2020, from June 8 to June 28, 2020 by means of Decree No. 521/2020, from June 29 to July 17, 2020 by means of Decree No. 577/2020, from July 18 to August 2, 2020 by means of Decree No. 604/2020, from August 3 to August 16, 2020 by means of Decree No. 642/2020, from August 17 to August 30, 2020 by means of Decree No. 678/2020, from August 31 to September 20, 2020 by means of Decree No. 715/2020, from September 21 to October 11, 2020 by means of Decree No. 755/2020, from October 12 to October 25, 2020 by means of Decree No. 794/2020, from October 26 to November 8, 2020 by means of Decree No. 815/2020 and, finally, from November 9 to November 29, 2020 by means of Decree No. 876/2020.

As of the extension provided by Decree 604/2020, all procedures carried out under the Federal Procurement Regime provided by Decree 1023/2011 and its amending regulations have been excluded from the suspension of the administrative procedures.

Decree 876/2020 after providing for the last extension of the suspension of the administrative procedures, determined to resume as of November 30, 2020, the course of the terms that were duly suspended by Decree No. 298/20 and its complements.

It will be important to analyze how this suspension of terms is applied and its impact on ongoing administrative procedures, as well as the exceptions that could be provided by certain entities or agencies in the specific procedures under their jurisdiction.