JULY 21, 2020

Necessity and Urgency Decree No. 604/2020: extension in administrative terms suspension.



Public Law Department report | Necessity and Urgency Decree No. 604/2020: extension in administrative terms suspension

Dear Sir or Madam,

Within the state of sanitary emergency currently in force, the National Executive Branch extended the suspension of the terms in administrative procedures through August 2nd, 2020.

Terms suspension in Federal administrative procedures: On July 21st the Federal Executive Branch issued Decree No. 604/2020, by means of which it extended the suspension of all terms in ongoing administrative procedures through July 18th up to, and including, August 2nd, 2020; it is worth reminding that, by means of Decree No. 298/2020, the Federal Executive Branch suspended terms in administrative procedures between March 20th through March 31st, said suspension was later extended five times up to July 17th (Decrees No. 327/2020, N°372/2020, No. 410/2020, No. 458/2020, No. 494/2020, No. 521/2020 and No. 577/2020). The terms suspension in administrative procedures and its extensions apply both to general administrative procedures under Law No. 19,549 –National Administrative Procedures Act–, as well as special administrative procedures regulated by sectoral legislation. Administrative procedures related to the health emergency are exempted from suspension.

Said suspension of terms does not affect: (i) statutory limitations to sue the Federal Government, (ii) the 90-days deadline to sue the Federal Government nor (iii) deadlines for filing judicial appeals since said terms must be computed in judicial working days. Nonetheless, said terms are also suspended during the judicial terms suspension which will be in effect through August 3rd, 2020 (Federal Supreme Court’s Resolutions 6/2020 and 27/2020). In accordance with the Federal Supreme Court’s Resolution 6/2020, during the extraordinary judicial recess, all judicial proceedings and terms will be also suspended, except for urgent matters such as criminal procedures, family matters or healthcare access requests.

Should you require any further information on this matter, please do not hesitate to contact us.


Juan Antonio Stupenengo
Vicente Kenny