What Is the Service Date of an E-Notification?
Electronic notification (e-notification) is an official notification method carried out under Notification Law No. 7201 and the relevant regulation, mandatory for some recipients and optional for others. Unlike physical service, the document here is not delivered to the recipient’s post box but to the electronic notification address assigned to them. In practice, the most commonly confused point is not the question of "when it was read", but "when it is deemed served". This is because the start of periods such as filing a lawsuit, objecting, appealing, or making a payment depends not on the day the message was read, but on the legal service date set by law.
For this reason, the critical question for a lawyer or a recipient is this: from which day does a document arriving at my electronic notification address start the running of a period? The answer to this question is of great importance in order to avoid a loss of rights.
Legal Basis: The End-of-the-Fifth-Day Rule
The service date of an electronic notification is regulated in Article 7/a of Notification Law No. 7201 and in the Electronic Notification Regulation. Accordingly, the basic rule is clear: a notification made electronically is deemed to have been made at the end of the fifth day following the date on which it reaches the recipient’s electronic address. In other words, the relevant date is not the day the document lands in the system, but the end of the fifth day following that day.
The rationale of this arrangement is to grant the recipient a reasonable period to examine and evaluate the document. Even if the recipient opens and reads the document earlier, the service date is still, by law, deemed to be the end of the fifth day; reading it early does not bring the period forward. In this respect, e-notification contains a buffer period in favour of the recipient. Conversely, even if the recipient never opens the document, the notification is deemed to have taken place at the end of the fifth day, and the periods begin to run.
How Is the E-Notification Date Calculated?
In practice, the calculation logic consists of two steps:
- Determining the date of arrival: The day on which the document reaches the recipient’s electronic notification address is identified. This is the date recorded by the system.
- Adding five days: The end of the fifth day following the date of arrival is accepted as the legal service date. The period begins to run on the day after the day of arrival and is completed at the end of business (at the end of the day) on the fifth day.
By way of example, if a document reaches the recipient’s e-notification address on 1 March, the end of the fifth day following that day, namely the end of 6 March, becomes the legal service date. From that date, the period provided for in the relevant law (for example 7 days, 15 days or 2 weeks) then begins to run separately.
Are the Service Date and the Start of the Period the Same Thing?
No. These two concepts are frequently confused with one another. The service date is the day on which the notification legally takes place (the end of the fifth day). The start of the period, on the other hand, begins to run from the day following the service date. That is, the service date is found first, and then the calculation of the relevant period (filing a lawsuit, objection, appeal) is carried out from that date. Additional rules also come into play in calculating the period, such as which moment is taken as the start of the day and the situation where the last day of the period falls on a holiday.
Points to Pay Attention To
- Reading early does not change the period: Even if the recipient opens and reads the document on the day of arrival, the service date is still the end of the fifth day. The moment of reading does not bring the service date forward.
- Weekends and holidays: If the last day of the five-day period falls on an official holiday or a weekend, how the service date and the associated periods shift requires an assessment of the specific case and the relevant procedural rules. For this reason, the tool’s result should be used as a guiding starting point.
- Correctly determining the date of arrival: The accuracy of the calculation depends on correctly entering the date on which the document reached the electronic address. This date should be confirmed from the records of the e-notification system (UETS).
- Mandatory recipients: This rule is particularly important for persons and institutions required to hold an e-notification address, such as lawyers, notaries, public institutions and companies; the period runs even if the document is not opened.
Common Mistakes
- Assuming the day of arrival is the service date: The most common mistake is to treat the day the document lands in the system directly as the service date. In fact, the rule is the end of the fifth day following the day of arrival.
- Taking the reading date as the basis: Some recipients evaluate the day they read the document as the service date. What is legally decisive is not the reading but the end of the fifth day.
- Confusing the service date with the last day of the period: The service date is a starting point; it is not the last day of the period for filing a lawsuit or objecting. These two must be calculated separately.
- Assuming the five days are "working days": The five days in the rule are based on calendar days; it is not a working-day calculation. Overlooking this distinction may lead to a shift in the period.
A Short Example Scenario
Suppose a document relating to an administrative sanction decision reaches a company’s electronic notification address on Thursday 10 April. Under the end-of-the-fifth-day rule, the notification is deemed to have taken place at the end of the fifth day following 10 April, namely at the end of 15 April. Even if the company opens and reads the document on 11 April, the service date still remains 15 April. If the period for objecting to this decision is 15 days from service, this 15-day period begins to run from the day following 15 April. As can be seen, if the calculation is done incorrectly, a shift of a few days may cause the right to object to be lost entirely.
Conclusion
In e-notification, the service date is the end of the fifth day following the day the document reaches the electronic address, and all associated legal periods are calculated on the basis of this date. The calculation tool above is designed to help you quickly find the legal service date starting from the date of arrival. However, since weekends, official holidays, the shifting of the last day of the period and procedural rules specific to the concrete case may affect the outcome, in situations carrying a risk of loss of rights it is strongly recommended that you consult a lawyer and confirm the notification records through the official system. This content is for information purposes only and does not constitute legal advice.