Countries › Paraguay › Guide › 14. Disputes › Claims against the State in Paraguay: administrative appeals, the Tribunal de Cuentas and arbitration of public contracts

Claims against the State in Paraguay: administrative appeals, the Tribunal de Cuentas and arbitration of public contracts

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Last verified: 2026-10-28 · Status: Stable

Challenging a ministry, regulator or municipality usually means first exhausting administrative appeals under the 2021 administrative procedure law: reconsideration within 10 days, then a hierarchical appeal within 10 days, each to be decided in 20 days or deemed rejected. The contentious administrative action then goes to the Tribunal de Cuentas within 18 business days of the decision that exhausts the administrative route, and the case lapses after 3 months of inactivity. Contract disputes with state bodies can instead be arbitrated where the contract has an arbitration clause, under Ley 7561/2025.

USD figures use PYG 5,868.31 per US dollar, the Banco Central del Paraguay reference quotation published for Wednesday 28 October 2026. Conversions are for orientation only.

Key facts

Time to file administrative reconsideration	10 daysLey 6715/2021 art. 64, as of 2026-10-28 · in force
Time to file hierarchical appeal	10 daysLey 6715/2021 art. 66, as of 2026-10-28 · in force
Time for the administration to decide each appeal (silence is rejection)	20 daysLey 6715/2021 art. 65, 67, as of 2026-10-28 · in force
Time to file the contentious administrative action	18 business daysLey 6715/2021 art. 69; Ley 4046/2010, as of 2026-10-28 · in force
Court for contentious administrative cases	Tribunal de Cuentas (two chambers) Poder Judicial, Tribunal de Cuentas page, as of 2026-10-28 · in force
Contentious administrative case abandoned after inactivity	3 monthsLey 1462/1935 art. 8, as of 2026-10-28 · in force
State entities may arbitrate contract disputes	Yes, unless exclusively public law; arbitration at law and public Ley 7561/2025 art. 2, as of 2026-10-28 · in force
Administrative procedure law in force	One year after publication on 29 September 2021 Ley 6715/2021 art. 90, as of 2026-10-28 · in force
BCP reference rate used for conversions	5868.31 PYG per USDBCP planilla 28 October 2026, as of 2026-10-28 · in force

The rule

1. Administrative appeals. Ley 6715/2021 sets the general regime for administrative acts and procedures of all state bodies exercising administrative functions. A reconsideration appeal against final decisions must be filed with the authority that issued the act within 10 days of notification; that authority has 20 days to decide, and silence means rejection. A hierarchical appeal may be filed against the rejection, or directly against the act, within 10 days of notification or of expiry of the time to decide reconsideration, before the highest administrative authority of the body, which must call for the file within 48 hours and decide on the merits within 20 days, silence again meaning rejection. The administrative route is exhausted by a decision of the highest authority, a decision on reconsideration where no hierarchical appeal lies, a decision on the hierarchical appeal, or acts against which no administrative appeal is available. The law was published in the Gaceta Oficial on 29 September 2021 and entered into force one year after publication.
Cost to do it: No fee for administrative appeals is set in these articles; counsel time.
Example: A company fined by a regulator on 2 November 2026 files reconsideration within 10 days; if no decision comes within 20 days, it treats the appeal as rejected and files the hierarchical appeal within 10 days. / For a fine of US$50,000 (PYG 293,415,500), a missed 10 day window leaves the act firm.Ley Nº 6715/2021, De Procedimientos Administrativos (Gaceta Oficial Nº 195, 29 September 2021), Art. 64, 65, 66, 67, 68 and 90, 2021-09-29 official text · verified 2026-10-28

2. Contentious administrative action. Once the administrative route is exhausted, the interested party may sue within 18 business days from the day after notification of the decision exhausting it; where exhaustion results from tacit rejection, the period runs from the end of the time the administration had to decide, but the right persists until the party is personally notified of the tacit rejection. Under Ley 1462/1935 the action lies against final administrative decisions issued under regulated powers that infringe a pre established administrative right of the claimant, where no other case on the same matter is pending; the Código Procesal Civil applies to the procedure, the case is deemed abandoned with costs on the claimant after 3 months without any procedural step, and costs fall on the losing party unless exempted. Ley 4046/2010 (as amended by Ley 5456/2015) set the 18 day period for appeals against any administrative resolution and repealed special periods in other laws. The Tribunal de Cuentas, with two chambers of three members each, hears contentious administrative cases exclusively.
Cost to do it: Court costs and lawyer fees under the general scale; the claimant bears costs if the case is abandoned (Ley 1462 art. 8).
Example: A licence revocation notified on Monday 2 November 2026 that exhausts the administrative route must be challenged before the Tribunal de Cuentas within 18 business days. / Challenging a US$1,000,000 (PYG 5,868,310,000) tax or customs decision requires meeting the same 18 business day window.Ley Nº 6715/2021; Ley Nº 1462/1935 as amended by Ley Nº 4046/2010 and Ley Nº 5456/2015, Ley 6715 art. 69; Ley 1462 art. 3, 4, 5, 8 and 9, 2010-07-27 official text · verified 2026-10-28

3. Arbitration with state bodies. State bodies under the state organization law, municipalities, state owned companies and binational entities may submit their contracts and differences with private parties to arbitration unless the matter is governed exclusively by public law. Where a contract contains an arbitration agreement and an administrative act terminates or rescinds it for the contractor's breach, or the act concerns a dispute on performance or interpretation, the matter goes to the arbitral tribunal to the exclusion of the civil and contentious administrative courts. Arbitration involving the State is always at law and public. The investment law also allows state entities contracting with foreign investors to agree on national or international arbitral tribunals.
Cost to do it: Arbitration costs follow the clause and Ley 7561 art. 64 to 68; no confidentiality.
Example: A road builder whose contract is rescinded by ministerial resolution for alleged delay goes to the arbitral tribunal under the contract, not to the Tribunal de Cuentas. / On a US$1,000,000 (PYG 5,868,310,000) claim under a public contract with an arbitration clause, the award will be public.Ley Nº 7561/2025, De Arbitraje; Ley Nº 117/1991, De Inversiones, Ley 7561 art. 2 and 42; Ley 117 art. 9, 2025-12-23 official text · verified 2026-10-28

Step	Deadline	Decision time	Source
Reconsideration	10 days from notification	20 days, silence is rejection	Ley 6715 art. 64, 65
Hierarchical appeal	10 days	20 days, silence is rejection	Ley 6715 art. 66, 67
Contentious administrative action (Tribunal de Cuentas)	18 business days from exhaustion	Procedure under CPC; lapse after 3 months of inactivity	Ley 6715 art. 69; Ley 1462 art. 5, 8
Contract with arbitration clause	As per clause	As per Ley 7561	Ley 7561 art. 2

Challenging an administrative act

Worked example

A foreign owned telecom operator receives a regulatory fine of PYG 293,415,500 (US$50,000). It files reconsideration within 10 days; the regulator does not answer in 20 days, so the appeal is deemed rejected. It goes directly to the hierarchical appeal within 10 days, unless the regulator's head issued the act, in which case the administrative route is already exhausted. It then sues before the Tribunal de Cuentas within 18 business days and must keep the case moving, since 3 months of inactivity ends it with costs.

Step by step

Diary the 10 day appeal windows from notification of the act.
Track the 20 day decision periods and treat silence as rejection.
Check if the act comes from the highest authority: if so, the administrative route may already be exhausted (Ley 6715 art. 68).
File the contentious action within 18 business days of exhaustion.
For contracts with state bodies, negotiate an arbitration clause; Ley 7561 art. 2 gives it priority over the courts.

Common traps

Ley 1462/1935 and Ley 4046/2010 speak of 18 days while Ley 6715/2021 says 18 business days; count conservatively.
Ley 1462 art. 3 requires the tax or account liquidation ordered to be paid before suing, a requirement still in the BACN text; check whether it applies to your case.
A contentious case is abandoned after only 3 months without activity, shorter than the 6 months in civil cases (Ley 1462 art. 8).
Arbitration with the State cannot be decided in equity (Ley 7561 art. 2 and 42).

Sources

← Mediation and conciliation in Paraguay: voluntary mediation under Ley 1879/2002 and court approved settlementsInsolvency in Paraguay: creditors' meeting (convocatoria), bankruptcy (quiebra), claw back and ranking of claims under Ley 154/1969 →

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