Key legal question
Whether the foundation had to issue administrative decisions before suing for unpaid contributions for 2007-2010
Extracted holding
Before 1 January 2011, the foundation had no administrative decision-making power for these contributions and could use an administrative action instead.
Extracted reasoning
The statutory framework before the 2011 ordinance amendment did not expressly or implicitly confer a decision-making power. The later Article 68a OFPr introduced such power and could not apply retroactively.