Author: Dr. Juan José Tubio
Paper Submitted and Approved by the Technical Committee of the 14th International Conference on Customs Law (AAEF, August 7 and 8, 2025).
The digitalization of administrative procedures is no longer an option, but a necessity. In the Argentine customs field, although significant technological tools have been incorporated in recent years, a structural problem persists: the coexistence of electronic systems with paper-based processing.
This paper analyzes the current challenges and proposes the implementation of the customs electronic case file as a key tool to strengthen due process, improve administrative efficiency, and ensure greater transparency in proceedings.
Objective of the Paper
The purpose of this paper is not to criticize the paper-based processing of customs procedures, but rather to present the advantages that the implementation of the electronic case file would bring as a necessary tool for the State to effectively fulfill its duty to guarantee the rights of individuals, ensuring:
- Due Process
- Transparency
- Efficiency
- Legal Certainty
The growing demand for speed, predictability, and simplification from the foreign trade sector, as well as the commitments assumed by our country in the field of trade facilitation, make an in-depth analysis of the feasibility of this structural transformation essential.
Background: Evolution of Customs Systems in Argentina
In recent decades, the Customs Service has advanced in the incorporation of technology through different systems that have transformed foreign trade operations.
Malvina Information System (SIM)
In December 1993, the former María Information System was launched, later modernized until it became the current Malvina Information System (SIM) in 2013.
This system made it possible to digitize import and export transaction documentation, generating greater operational efficiency.
SICNEA: Customs Electronic Notifications
Under the motto "a Customs with less paperwork", in 2013 the following was implemented Customs Electronic Communication and Notification System (SICNEA).
Its purpose was to simplify communication between the Administration and foreign trade operators, replacing paper notifications.
It currently constitutes a well-established tool that provides:
- Legal Certainty
- Speed in communications
- Greater transparency
- Lower administrative costs
VUCE: Single Window for Foreign Trade
The VUCE, Created in 2014, it centralized the management of authorizations and certifications required to process import, export, and transit operations of goods.
It allowed information and documentation to be unified in a single portal.
SITA: Customs Procedures Computer System
In 2015, the SITE, as a mechanism to channel communications and presentations to the General Directorate of Customs.
Over time, its use expanded, allowing multiple digital procedures by operators.
GDE and Remote Procedures (TAD)
The system was created in 2016 Electronic Document Management (EDM) as an integrated platform for labeling, numbering, tracking and registration of files of the National Public Sector.
For their part, Remote Procedures (TAD) It allowed citizens and businesses to interact digitally with public bodies through:
- Presentations
- Applications
- Writings
- Notifications
- Remote case tracking
Current situation: challenges of parallel processing
Despite the implementation of the tools mentioned, one of the main current challenges is the simultaneous processing of paper files and administrative acts issued digitally through GDE, without a real systemic integration.
Problems generated by this hybrid model
- Lack of transparency
- Processing delays
- Documentary fragmentation
- Operational difficulties for officials and the public
- Violation of due process
- Impact on legal certainty
The coexistence of physical and electronic procedures without efficient linking prevents the consolidation of a modern and coherent system.
SUGA 2024: Single Customs Management System
In 2024, the Single Customs Management System (SUGA), designed to allow unified, efficient and coordinated management of administrative and judicial actions.
It anticipates interoperability with systems such as:
- SIM
- SIGEA
- GDE
- SICNEA
- SITE
- SIRAEF
As of the date of this publication, no significant progress has been observed in its full implementation.
Successful experiences in other public bodies
The adoption of electronic records in other state areas demonstrates their feasibility and concrete benefits.
National Public Administration
Currently, with few exceptions, most procedures are handled through TAD, which has allowed:
- Reduce processing times
- Increase transparency
- Facilitate remote access
- Eliminate dependence on paper
- Real-time tracking
National Tax Court
By means of Agreement No. 1/2019, the National Tax Court It implemented electronic case files for new cases starting in May 2019.
The overall balance has been positive, improving:
- Procedural speed
- Remote presentations
- Electronic notifications
- Document security
- Comprehensive traceability
Electronic file and constitutional guarantees
The State has the obligation to establish suitable procedures for the defense of the rights of those subject to its administration.
Right to defense and access to the file
Access to the file is a central aspect of due process and is recognized in national administrative regulations.
However, in practice, accessing customs procedures is often complex, which hinders the technical defense.
Implementing electronic records would allow:
- Full and permanent access
- Immediate remote consultation
- Greater procedural predictability
- Better exercise of the right to defense
Principles that it strengthens
- Effective administrative protection
- Transparency
- Good management
- Simplification
- Speed
Guarantee of a reasonable time frame
Everyone has the right to obtain a resolution within a reasonable time.
Excessive delays in customs proceedings and administrative actions violate constitutional guarantees. Electronic filing would help reduce processing times and improve administrative efficiency.
International framework and commitments undertaken
Kyoto Convention
The International Convention for the Simplification and Harmonization of Customs Procedures emphasizes the maximum use of information technology.
The electronic record aligns directly with these principles of:
- Simplification
- Modernization
- Harmonization
- Trade facilitation
Trade Facilitation Agreement (WTO)
The Agreement promotes:
- Streamlining the movement of goods
- Regulatory transparency
- Digital access to information
- Effective review procedures
In this context, the electronic file constitutes an effective tool to achieve these objectives.
Conclusions: Implementation of electronic records is necessary
The lengthy processing times for customs files, coupled with access difficulties, make it necessary to implement a single, traceable and secure system for both Customs and foreign trade operators.
It is essential to develop a proprietary system that can be operated within the website of ARK, with access via Tax ID, guaranteeing:
- Information privacy
- Authorized operator access
- Access for intervening lawyers
- Integration with SICNEA
- Full traceability of the file
Final vision: a modern and efficient Customs
In a context where digitization is no longer an option but a necessity, the implementation of electronic files in customs procedures is presented as a key tool to guarantee a more agile, transparent, accessible procedure that respects constitutional guarantees.
The effective integration of existing systems, along with the creation of a specific module accessible with a Tax ID, would allow for the optimization of resources, the reduction of costs, and compliance with the international commitments assumed by the Argentine Republic.
Dr. Juan José Tubio
- Partner and Legal Director of MJE Comercio Exterior SRL
- Lawyer specializing in Customs Law
- Graduate of the University of Buenos Aires
- Senior Technician in Customs Clearance
- Associate Member of the Argentine Association of Fiscal Studies
- Member of the Public Bar Association of the Federal Capital
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