The Basque Government has announced four penalty proposals for security rule violations at Erandio

The Department of Security of the Basque Government has announced four sanction proposals today in issue number 216 of the Official Gazette of the Basque Country (BOPV) dated November 11. Asier Erkoreka Arruza, Director of Security Coordination, signed the set of resolution proposals in Erandio on October 29, and the announcement serves as a substitute for personal notification. The proposals are based on alleged violations of Organic Law 4/2015 on the Protection of Citizen Security and Law 5/2014 on Private Security.

The notification had to be carried out via public notice. The Department’s services attempted personal notification, but without success, and therefore the announcement was published: Article 44 of Law 39/2015, of October 1, provides for this method when the notification cannot be delivered directly to the interested party. The text itself specifies that the notification will take effect from the day after its publication in the BOE, and the interested parties are the persons listed in the annex.

This type of announcement is not new to the Department of Security. The directorate of Security Coordination has published similar regular announcements in the BOPV this year, among others on October 23 and August 14, always in files related to violations of Organic Law 4/2015 and Law 5/2014. The publication rhythm shows that a large portion of sanction files follow the path of subsidiary notification.

Details of the four files and penalties

The attached annex includes four files, with their corresponding reference, date of occurrence, proposal date, and penalty amount. In three cases, Article 36 of Organic Law 4/2015 is involved, and in one, Article 37.17:

• 405X2600278-03: a fine of 100 euros, violation of article 37.17; the occurrence took place on September 11, 2025, and the proposal is dated September 14, 2026.
• 405X2602286-06: a fine of 602 euros, violation of article 36.06; occurrence on July 6, 2025, proposal on September 30, 2026.
• 405X2604826-01: a fine of 2,500 euros and an order to surrender weapons, violation of article 36.10; occurrence on February 5, 2026, proposal on September 17, 2026.
• 405X2605148-07: a fine of 602 euros, violation of article 36.06; occurrence on October 2, 2025, proposal on September 14, 2026.

The total amount of penalties for the four files is 3,804 euros, to which the order to surrender weapons must be added. The file references have the number 405X2600 in the section, and therefore belong to the same 2026 processing line. The largest penalty, 2,500 euros, corresponds to a violation in the area of weapons.

Ten working day period for allegations

Along with the notification of the proposals, interested parties are granted a period of ten working days to submit allegations and deliver any documents and information they deem appropriate. The period is counted from the day following the publication of the announcement, and allegations, according to the published text, must be addressed to the body instructing the file: the Director of Security Coordination, at the Directorate of Security Coordination under the Department of Security.

There is also the possibility to consult the file in its entirety, citing the file number. For this purpose, the interested party must go to the Directorate of Security Coordination, at the address Larrauri Mendotxe Bidea, 18, in Erandio. Failure to submit allegations does not stop the procedure: the administration must issue a resolution, but the content of the proposal may become almost definitive if the interested party makes no allegations.

Effects of the subsidiary notification

The announcement is not a standard communication; it is a substitute notification enabled by Article 44 of Law 39/2015, and it must be considered an individual notification for the interested party. Consequently, the counting of the ten-working-day period is not delayed, and subsequent appeal periods also take the publication date as a starting point. Even if the interested party lives abroad, the notification is valid upon publication in the BOE.

Therefore, the publication has a practical effect for those sanctioned. On one hand, it opens the last administrative opportunity to oppose the penalty; on the other, if the deadline passes, it facilitates the path for the proposal to become a resolution, making it much more difficult to pursue judicial channels later. Similarly, the publication ensures the transparency of the procedure, so that the penalty does not remain in an unjustified silence.

Impact on interested parties

The proposals for the four files mostly include economic penalties, but in one case, there is also another security-area measure: the surrender of a weapon. This measure has a direct impact on the daily life of the sanctioned person, and consequently, there is a great urgency to prepare allegations within the ten-working-day period. Regardless of the extraordinary notification, interested parties have the same guarantees as in an ordinary procedure.

Furthermore, the announcements reveal the volume of the management of sanctioning files: four files were published in a single day, and similar announcements have been common in recent months. The Department of Security has not provided general data on the total number of notifications published this year, but following the publications in the BOPV confirms this trend.

Source: Official Gazette of the Basque Country, number 216, November 11, 2026, Other official announcements (official reference: 2026/4782).