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.
What the law says
- 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.
Practical examples
- 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.
Common mistakes
- 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.
How 4softhr helps
- 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.