Electronic court filings: delegated public authorities

April 2026 · Written on 13 November 2026. The month refers to the stated decision or effective date.

On 23 April 2026, in case 2 C 11.25, the Federal Administrative Court held that the mandatory electronic filing rule in section 55d VwGO also applies to private entities entrusted with public powers when acting as authorities in a functional sense. Private-law organisation does not itself exclude the duty.

Practical implications

The issue concerns valid submission of court documents, not merely a convenient technical channel. Bodies exercising public functions should review roles, submission routes and receipt checks. Exceptions for technical disruption have specific requirements. The judgment should not be read as imposing an undifferentiated new obligation on ordinary private parties.

Four practical examples

Illustrative scenarios, not accounts of client matters. The appropriate response depends on the documents, applicable law and procedural position.

Documents and next steps

The body's legal mandate, procedural role, filing documents, submission records and any technical incident evidence.

Keep the relevant contract or decision, correspondence and all service and event dates. Identify the outcome you want and any running deadline. For urgent matters, please also call the office.

Source: Official source and further reading. Editorial legal position: 13 November 2026.