The administrative procedure regulations allow the action of the interested parties to be carried out through a representative, a condition that can be accredited with any legally valid means that leaves reliable evidence of its existence (article 5 of Law 39 /2015, of October 1).
Among others, two of these means are i) the accreditation of the registration of the representation in an electronic register of powers of attorney (such as REPRESENTA) and, ii) the qualified electronic certificate of representative (article 32 of Royal Decree 203 /2021, of March 30).
In practice, especially when the interested parties are legal entities (and therefore subject to the electronic relationship), it is common to use representative certificates.
In this case, doubts may arise about the need, or not, to register the representation contained in the electronic certificate in REPRESENTA.
It should be borne in mind that the qualified electronic certificate of representative is issued in compliance with the regulations governing trust services, which require verification of the representation relationship (Regulation 910/2014 (ReIDAS) and Law 6/2020, of November 11).
Therefore, since these certificates already attest, by themselves, the relationship of representation existing between two people, it is not necessary to register the representations in REPRESENTA.
When you try to register the representation contained in a certificate of representative, that is to say, when you try to register that the natural person contained in the certificate represents the legal entity contained in the same, the platform returns a warning: It is not possible to register this combination of NIFs.
This is so, given that as indicated in the previous section of this same FAQ, the representative certificate already accredits the existing representation relationship between these two people, therefore, it is not necessary to register this representation in the REPRESENTA.
The same thing happens in reverse, when you try to register that the legal person appearing in the certificate represents the natural person appearing in the same, given that it is a representation that does not apply.