Who is obliged to submit data in REGES — the employer or the accountant?

Quick answer

The legal obligation to submit data in REGES lies with the employer.
The employer can delegate the actual operation to an authorised agent — an HR employee or an external provider.
The external provider can be an accounting or payroll firm, authorised through access in the platform.
Delegation is done by granting REGES access to the authorised person or firm.
Legal liability for accuracy and deadlines stays with the employer, even when someone else operates.

The employer holds the obligation to register data in the general employee records registry.
Operation can be delegated to an authorised agent (employee or external provider) by granting REGES access.
Delegating operation does NOT transfer administrative liability, which remains the employer's.
The Labour Code (Law 53/2003) and registry legislation set out the obligation and the sanctions.

Example: a company with an HR specialist grants them REGES access to operate the submissions.
Example: a small firm outsources payroll to an accounting firm, which is given REGES access.
Example: even if the accountant performs the submission, the fine for a delay is applied to the employer.

Believing that, once payroll is outsourced, legal liability automatically passes to the provider.
Granting REGES access without monitoring whether submissions are actually made on time.
Lacking an internal record, so the employer cannot check what the authorised agent submitted.
Not revoking a provider's access after the collaboration ends.

4softhr gives the employer full visibility over contracts, regardless of who operates in REGES.
It allows delegating tasks to HR or the accountant while keeping a centralised, auditable record.
It sends deadline alerts to both the employer and the authorised operator.
It keeps the change history so the employer can check at any time what was submitted.
It reduces the risk that the employer's legal liability is affected by an omission of the provider.