EU Grants

GRANTS - BASICS
Participants' course manual
DG BUDG – Central Financial Service
January 2015
CONTENT
Introduction 3
1 Before launching a grant procedure 5

1.1 Procurement or Grant? 5
1.2 Basic principles 6
1.3 Types and forms of grants 7
1.4 Background information (Content of a call for proposals,
pre-conditions and legal framework, financial actors) 9
2 Prepare your call 12

2.1 Prepare your work schedule & 1 step or 2 steps procedure 13
2.2 Draft your call documents (Content, legal commitment) 14
2.3 Pre-financing guarantee 27
3 Publicity, transparency and contacts 28

3.1 Publicity and transparency 28
3.2 Access to call documents 30
3.3 Contacts and confidentiality 31
4 Award step by step 32

4.1 Opening and evaluation 32
4.2 Award decision and information to applicants 36
4.3 Commitments 38
5 Implementation phase 39
5.1 Payments 39
5.2 Implementation problems 42
5.3 The Early Warning System 43
5.4 Filing and Controls 43
6 Reference legislation 45
Grants participant's manual 2

INTRODUCTION
What are Grants?
Grants are direct financial contributions from the European Union budget
awarded by way of a donation to a third-party (= the beneficiary1) engaged in
activities that serve Union policies.
Grants are a type of expenditure financed by the EU budget that is managed

by the Commission, either directly by its own departments, or by executive
agencies and EU delegations in third countries (direct management mode).
If certain conditions are met, the Commission may delegate the management
of EU the budget to international organisations, traditional agencies or
national agencies (indirect management). These organisations may be
authorised to award grants to third parties. Member States can also award
grants with EU funds under shared management.
The key principles applicable to grants managed directly by the Commission
also apply to grants awarded in indirect management and shared
management, but the rules to be applied may differ.
This manual concerns only the rules applicable to grants managed directly by
the Commission, rules which stem from the Financial Regulation (FR) and its
Rules of Application (RAP).
Grants fall into two broad categories:
 grants for actions intended to help to achieve an objective that forms

part of an Union policy;
 operating grants that finance the operating expenditure of a body

pursuing an aim of general European interest or an objective that
forms part of an Union policy;
In the case of grants, we don't receive anything in return as it is the case in

public procurement, where goods or services are provided for the institution
in exchange for payment. Grants represent the EU contribution to the
implementation of an action and are based on costs incurred by the
beneficiaries of the grant for carrying out the activities in question. The
results of the action remain the property of those beneficiaries.
1
Definition of a "beneficiary": A moral person or entity, whether private, public or semi-public, that is
responsible by the signature of the grant agreement (contract) for the coordination and management of the
project, including the dispatch of the funds. The beneficiary is the one who receives the grant and who reports
directly to the Commission. Beneficiaries are solely and totally responsible for implementing the action or the
work programme defined in the grant.

How to use this manual?
This manual is a complement to the grants basics training that you followed.
It is intended for enabling you to do not only your first steps in the world of
grants management, but also as reference document, for the follow-up and
management of your procedures and grant agreements/grant decisions.
The manual includes information on all basic aspects of a grants procedure.
Chapter 1 describes the framework and principles in which the Union's grant
management is carried out and provides for background information.
Chapter 2 is about how to prepare your call for proposals2 and the choices
for your call.
Chapter 3 explains how we respect the principle of transparency via publicity

and contacts with the beneficiaries.
Chapter 4 details the steps that have to be taken for the award of a grant
(grant agreement/grant decision), while information on the main aspects of
grant management including implementation problems and audit and
controls are included in Chapter 5.
The reference legislation is provided in Chapter 6.
This manual does not replace the Grants Vade-mecum which contains
detailed interpretations and good practices applicable to managing grants on
the Commission's own account and which can be found on BudgWeb.
BudgWeb is the Commission's internal financial website which contains

information on grants in the section on the implementation of the EU budget.
Besides the Vade-mecum you can find there further specific guidance and all
relevant model documents, such as models for grant agreements and grant
decisions, model application forms, model declarations and other useful
templates.
2
Call for proposals = Procedure used to identify the most deserving actions or entities to be
financed by the European Union
4 Grants participant's manual

1 Before launching a grant procedure 5
1.1 Procurement or Grant? 5
1.2 Basic principles 6
1.3 Types and forms of grants
1.3.1 Action grants and operating grants 7

1.3.2 Forms of grants (lump sum, unit costs, flat rate etc.) 8
1.4 Background information 9
1.4.1 Content of a call for proposals 9

1.4.2 Pre-conditions & legal framework 9
1.4.3 Who does what when launching a procedure (financial actors) 11
1.1 Procurement or Grant?
As a general rule, the difference between public procurement and grants is

fairly clear. Briefly, in the case of procurement the Commission obtains (buys)
a product or service it needs in return for payment, while in the case of a
grant it makes a contribution to the beneficiary in order to implement an
action or cover its running costs because the beneficiaries' activities
contribute to EU policy aims.
Procurement = buying Grant = support

Public procurement represents a part of the Union’s expenditure. It is defined
as a purchase by a public authority (the Commission or other Institutions and
Agencies) of services, goods or works.
Grants are direct financial contributions from the European Union budget
awarded by way of a donation to beneficiaries engaged in activities that serve
Union policies. Grants are covered either by a written agreement (grant
agreement = GA) or by a Commission decision (grant decision = GD) to the
successful applicant for a grant which becomes the "beneficiary". We can
have mono-beneficiary and multi-beneficiary GD/GA (see point 2.2.2.1)
1.2 Basic principles
In grants management, you should pay particular attention to the following

guiding principles enabling you to always act and react sensibly:
Transparency
It means that we have to publish all relevant
information concerning our grants. It is a
requirement to inform the EU citizens and
potential applicants/beneficiaries about what
we are financing, possibilities to receive grants
and who received grants.
This publicity will keep the taxpayers informed
on how and with whom we spend their money.
Equal treatment and non-discrimination

All interested parties in the same situation will be
treated in the same way. An advantage, e.g. additional
information, given to one applicant must be given to all
other applicants.
Non-cumulative
The EU has to ensure that no costs are reimbursed twice
through EU grants.

No retroactivity
A grant cannot be used to cover costs of an action that
is already finished3. For operating grants, this principle
means in practice that grants may not start before the
budget/calendar year of the beneficiary.
Co-financing
We give a contribution to part of the costs; we
do not (with some exceptions to this principle)
pay the totality.
No profit
Grants shall not have
the purpose or the effect of producing a profit (=
revenue > costs) within the framework of the action
or work programme of the beneficiary (with some
exceptions).
1.3 Types and forms of grants

1.3.1 There are two broad categories/types of grants:
 Action grants that finance a project intended to help to achieve an

objective that forms part of an Union policy
 Operating grants that finance the "running costs" for the functioning of
a body pursuing an aim of general European interest or an objective
that forms part of an Union policy
Examples of action grants:
Scholarships ("Erasmus+"), research projects (under

"Horizon 2020" or "COSME"), exchange of practices between
authorities of Member States in the area of taxation
("Customs 2020"), construction of motorways across EU
Member States, vaccination programmes in third countries,
etc.
3
For actions that will begin before the signature, they could be funded only where the applicant can demonstrate
the need to start working before the start date of the grant. The call will announce that costs may be eligible as
from the date of submission of the proposal, but not earlier.

Examples of operating grants:
College of Europe (Bruges and Warsaw), EuroNews, European committee for

standardisation (CEN = Comité Européen de Normalisation, an
international non-profit association providing
European standards) etc. The Commission finances
the running costs of several non-profit
organisations, voluntary associations,
foundations, NGOs to implement a range of activities that
pursue their statutory objectives and which are in line with EU policies.
Operating grants cannot be awarded in the form of lump sum or flat rate
financing.
Action grants can be multi-annual, operating grants are always awarded on
an annual basis (linked to the accounting year of the beneficiary).
1.3.2 There are five forms of grants4:
Grants may take any of the following forms:

(a) Reimbursement of a specified proportion of
the eligible costs actually incurred by the
beneficiary;
(b) Reimbursement on the basis of unit costs;
(c) Lump sums;
(d) Flat-rate financing;
The forms b, c, and d are called "simplified forms of grants".
Lump sums: Flat rates: Unit costs:

(e.g. scholarships, website, (indirect costs e.g. (e.g. travel, hotel, hourly
publications, translations) for overheads) rate of staff costs)
%
4
Article 123.1 FR

(e) A combination of the forms referred to in points (a) to (d) which are the
so-called "mixed forms" of grants.
1.4 Background information
1.4.1 Content of a call for proposals
The European Commission prepares a "call for proposals" when it issues a

publication in which it describes the aims and priorities for funding required
for project. The call for proposals provides all necessary information about
the background (e.g. legal basis), the pursued objectives of the call, the
evaluation criteria, the available budget, the administrative arrangements and
the final date for submission of applications5, the planned date for
information to the applicants on the evaluation outcome, the intended forms
of grants (lump sums, unit costs, eligible costs occurred, mixed), the
procedural and supporting document requirements as well as the financing
modalities (co-financing rate, balanced budget, budgetary annex, payment
and reporting modalities).
It is only possible to submit a project proposal in reply to a call for proposals
published by the EC. A set of documents (call for proposals, grant application
forms, draft GA/GD, budgetary annex and declaration forms) is published for
each call and includes all the necessary documents to enable the applicants
to prepare a proposal. The call text indicates very precise deadlines that
must be respected.
1.4.2 Pre-conditions & legal framework

Before you launch a call for proposals, you have to make sure that the
necessary legal and budgetary pre-conditions are in place i.e. that the
(annual) Work Programme (WP) and the Financing Decision (FD) for your
future calls for proposals have been adopted (This is not necessary for
administrative expenditure budget lines, pilot projects and preparatory
actions) and that the work programme has already been published.
A legal basis is needed for any type of
expenditure. The legal basis can take
different forms depending on the type
of expenditure: for operational
expenditure (i.e. expenditure for the
implementation of EU policies), we
need a basic act (which can take the
5
The deadline should always be a fixed date - be careful that it doesn’t fall in a weekend or during official
holidays

form of a Council Regulation or Council and Parliament Regulation, of a
Directive or of a Decision).
In the case of administrative expenditure (i.e. expenditure for the functioning
of the institutions), we don't need a basic act as the EU treaty and the
Financial Regulation provide for the necessary legal basis.
However, grants on the administrative expenditure budget are very
exceptional (e.g. DGs COMM and SCIC).
Budget line and budget programming:
Make sure that the necessary funds for

your future grant have been included in
your budget line.
A work programme (= WP which can be multi-annual) and an annual

Financing decision (FD) are also required for every operational expenditure
(= implementation of EU policies). Both are adopted by the College of
Commissioners.
The Financing Decision can take two forms: either the work programme is
sufficiently detailed and therefore worth the Financing Decision, or if this is
not the case, we will have to adopt an "ad hoc
Financing Decision" in addition to the (annual6)
work programme. In any case, you need the FD
adopted before you launch a call for proposals.
Administrative expenditure covering the running

costs of the institution doesn't require a Financing
Decision.
6
Since the entry into force of the new FR also multi-annual work programmes are possible, but only the first
year of the work programme may constitute a Financing Decision (which always needs to be annual).

1.4.3 Who's does what when launching a procedure?
The Responsible Authorising Officer – RAO
The decisions concerning the procedure to organise

a call for proposals and to select the beneficiaries
are taken by the RAO in full consistency with the
basic act. The RAO decides for example on the
evaluation criteria i.e. the eligibility criteria (who can
apply), the eligible actions (training, research,
communication…) and eligible costs, the award
criteria (weightings and thresholds), the minimum
requirements for operational and financial capacity,
the payment modalities and the administrative
arrangements (submission deadline, 1 step or 2
steps procedure) etc.
The RAO appoints the evaluation committee, takes the decision on who will
be awarded the grant agreement(s) after the conclusion of the evaluation
procedure and finally validates the budgetary commitment and signs the
GAs/GDs.
The project manager (often OIA)

This is the key figure when it comes to the
management of the call and the implementation
of the action afterwards. All main documents
for the call will be drafted by the project
manager and he or she will ideally be part of
the evaluation committee. Once a GA/GD has
been signed, the project manager will usually
also be the person monitoring the
implementation of the action and usually
validate the financial transactions as
"operational initiating agent (OIA)".
The financial officer (often FIA)

In most cases, documents such as the GA/GD and the
financial criteria (co-financing rate, eligible costs,
budgetary annex to the GA) will be prepared or at least
checked by him/her working most likely as financial agent
in the project manager's unit (or the central finance unit of
a DG). A close communication between the project manager
and the financial officer is essential in order to ensure
coherent data in the call documents (also compared to the
BA and the WP/FD).

2 Prepare your call 12
2.1 Prepare your work schedule & 1 step or 2 steps procedure 13
2.1.1 Prepare your work schedule 13

2.1.2 The procedure in 1 or 2 steps 13
2.2 Draft your call documents 14
2.2.1 Content of a call for proposals 15
2.2.1.1 Objectives and expected results 15

2.2.1.2 Evaluation criteria 16
2.2.1.3 Financing modalities 19
2.2.1.4 Administrative information
(Submission modalities, supporting documents, templates) 20
2.2.2 The legal commitment 22
2.2.2.1 Mono-beneficiary & multi-beneficiary 22

2.2.2.2 Grant agreement / grant decision 24
2.2.2.3 Framework Partnership Agreement (FPA) 25
2.2.2.4 Third Parties – Subcontracting 26
2.3 Pre-financing guarantee 27

2.1.1 Prepare your work schedule
What should be the starting point of your
procedure? In order to gain an overview on when
the different steps of your procedure will be carried
out, you need to prepare an initial planning (road
map with all the steps to be attributed to the
staff/persons in charge and with realistically fixed
deadlines) that will also serve for the monitoring
later on.
You should check if check lists are available7 to
help you establishing the indicative planning and
avoiding that essential steps of the procedure
occur at inappropriate moments (e.g. launching the
call during Christmas time, deadline for submission on a public holiday or
carrying out the evaluation during the summer break).
2.1.2 The procedure in 1 or 2 steps

The expected number of applicants may determine the choice of the
procedure for submission in 1 or 2 stages/steps.
1 step procedure: The applicants submit all documents requested in the call
and the evaluation committee will evaluate them successively against the
announced criteria (eligibility, exclusion, selection and award).
2 steps procedure: Only applicants who pass a limited set of criteria go to the
next phase. It is up to the responsible authorising officer to decide whether
the objectives and the specificities of the call for proposals at stake make the
submission process in two steps appropriate or not.
The 2 steps procedure could

be useful e.g. when the call
for proposals is expected to
generate a large number of
proposals in relation to the
available budget. It could
save time by avoiding a full
assessment of proposals which are considered irrelevant or only vaguely or
partially relevant for the achievement of the policy objectives8. On the other
hand, the division of the submission in stages will tend to lengthen the
procedure!
7
See also Grants Vade-mecum: Establishment of a road map under section 4.3.3
8
Applicants submit e.g. only a summary of the project description (a few pages) and proof of their eligibility.
Those applications will be evaluated and ones who will pass the first stage will be invited to submit the full set
of documents requested in the call. They will then be evaluated based on the criteria detailed in the call.

Time to grant = TTG
Your work schedule should be established with due consideration to legal
time limits9, the time to grant which is a maximum of 9 months:
Call deadline +
The AOD has to report on the TTG in the Annual Activity Report!
The different phases of a call for proposals are the following:

- Publication of the call documents
- Submission of proposals
- Evaluation
- Award
- Information of successful and non-successful applicants
- Budgetary commitment
- Signature of the GA/GD
2.2 Draft your call documents
The call documents

They will provide the applicants with information on the concrete objectives
of your call/programme and the expected results, how you will assess their
proposals and what the contractual and financial conditions will be e.g. for
the co-financing and the payment modalities.
You will also provide administrative information such as the arrangements

for submission of documents, the deadline for the submission and the
timetable for the evaluation and future award. While having a similar
structure, different model documents need to be used according to the type
of grant (action or operating grant, mono-beneficiary or multiple
beneficiaries, framework partnership agreement etc.). You can find them on
BudgWeb10.
The basic principles applicable to grants as described in point 1.2 above and
consistency with the provisions of the basic act (see point 1.4.2), should
always guide you during the preparation of the call documents.
9
Article 128.2 FR on time to grant
10
http://myintracomm.ec.testa.eu/budgweb/EN/imp/grants/Pages/grants-agreement.aspx

2.2.1 Content of a call for proposals
The call documents include at least:
2.2.1.1 Objectives and expected results

2.2.1.2 Evaluation criteria
2.2.1.3 Financing modalities
2.2.1.4 Administrative information
Depending on your specific needs, you may have additional annexes, e.g.
information to applicants, guide for submission, model declarations (e.g.
declarations of honour in support of exclusion or selection criteria) etc.
The call documents have to be equally available to all potential applicants,

but the means to be used for the publicity may vary according to the
assessment of the RAO (see point 3. Publicity, transparency and contacts)
The Grants Vade-mecum and your DG's manual of procedures provide the
frameworks for drafting your call specifications/content so as to give
potential applicants all the necessary information on the funding
possibilities, your grant agreement provisions, the background to it and the
fine details.
The call for proposals will at least provide the following information:
2.2.1.1 Clear description of objectives and expected results
Define the objectives and expected results of the action (or the work
programme in case of operating grants) in a sufficiently detailed way in order
to ensure that the proposals will be coherent with the policy to implement.
(Check consistency with the basic act and the Work Programme / Financing
Decision!)
You should also pay attention to everything related to the deliverables (= the
output of the action(s) which is usually to be described in a report to be
provided by the beneficiary when the final payment will be requested).
What is the maximum duration of the action(s) and what are the milestones
and deliverables of the project?
Consultation with specialist DGs (e.g. DIGIT for IT projects) may help you in
the drafting of the call text.

2.2.1.2 Evaluation criteria
Eligibility criteria:
Eligibility criteria are used to determine whether an applicant is allowed to

participate in the call for proposals and to submit a proposal for an action or
work programme.
General eligibility criteria are related to the legal status of the beneficiaries
and should comply with specific provisions in the basic act, if any.
Grant applications are eligible if submitted by:

- legal persons
- natural persons (in so far as this is required, or at least permitted, by the
nature or characteristics of the action or the objective pursued by the
applicant)
Grant applications may also be eligible if submitted by entities which do not

have legal personality under the applicable national law (e.g. trade unions,
associations, foundations etc.) provided that their representatives have the
capacity to undertake legal obligations on their behalf, and offer guarantees
for the protection of the Union's financial interests equivalent to that offered
by legal persons and provide evidence that they have financial and
operational capacity.
Eligibility may be restricted (often in the basic act) to

certain categories of applicants who appear as the
natural target or relay for the sectorial policy.
You should also reflect on accepting applications

from consortia and on the eligibility of affiliated
entities (see point 2.2.2.4 below). In the event that
affiliated entities are allowed under the call for
proposals, these entities will have to demonstrate
that they satisfy the eligibility criteria and provide
the relevant supporting documents.
Exclusion criteria:
The objective of the exclusion criteria is to specify the cases in which

applicants would be excluded from participation in the call procedure or from
being awarded a grant. Situations questioning the integrity, ethics, the
regular legal operation of the applicant etc. form conditions for exclusion.

These are situations described in article 106 a) to f) of the FR such as
bankruptcy, grave professional misconduct, non-compliance with social or
tax obligations, involvement in a criminal organisation, money laundering or
any other illegal activity etc.
Applicants must declare on their honour that

they are not in one of the situations of
exclusion referred above. A declaration to this
effect shall be included in the grant application
to be signed by all applicants11
However, the RAO will refrain from requiring
such declarations for grants lower or equal to
EUR 60 000 or when such certification has
already been submitted for the purposes of
another grant or procurement procedure,
provided that the documents are not more than
one year old and that they are still valid.
For grants exceeding EUR 60 000 the RAO, depending on a risk assessment,
can request that successful applicants provide evidence required under
article 143 RAP (relevant documents are specified on the e-Certis website of
DG MARKT12).
Selection criteria:
The selection criteria aim to assess the applicant's ability
to complete the proposed action. Only proposals by
applicants who satisfy the selection criteria may be
considered for a grant. The necessary ability of the
applicant must be assessed under two aspects, both
financial and operational.
Financial capacity means that the applicant must have
stable and sufficient sources of funding to maintain his
activity throughout the period during which the action is
being carried out (or the year for which the grant is
awarded in case of operating grants).
For grants up to (and equal to) EUR 60 000, a declaration on honour in
support of the selection criteria has to be provided and is deemed sufficient.
For grants exceeding EUR 60 000, the financial capacity will be assessed13 on
the basis of documents required from the applicant such as recent annual
accounts, namely the balance sheet for the last financial year for which the
accounts were closed and the profit and loss account.
11
Forms of the "declaration of honour by the applicant" are available on BudgWeb
12
http://ec.europa.eu/markt/ecertis/login.do
13
Any ratios and the methodology to be applied in assessing the financial capacity shall be published with the
call for proposals for the sake of transparency

Operational capacity means the professional
competencies and qualifications required to complete
the proposed action. This operational capacity may be
assessed on the basis of specific qualifications,
professional experience and references in the field
concerned.
For grants up to EUR 60 000, a declaration on honour
has to be provided and is deemed sufficient.
For grants exceeding EUR 60 000, the operational capacity will be assessed
on the basis of documents required from the applicant such as CVs, a list of
previous projects and activities performed in the area, description of the
technical equipment, tools or facilities and patents at the disposal of the
applicant.
It is important that the call for proposals specifies the supporting documents
to be produced for the purpose of verifying the applicant's financial and
operational capacity against the announced requirements / thresholds.
Award criteria:
The award criteria aim to evaluate of the quality of the proposals in relation
to the objectives of the call. On the basis of these criteria, grants will be
awarded to those applications which maximize the overall effectiveness of
the Union's programme they implement. It is up to the RAO to decide
according to the objectives, priorities and the specificities of the call for
proposals the most suitable award criteria. These should be clear in view to
facilitate the evaluation.
Examples of award criteria:
- the relevance of the project and its expected results
- the effectiveness and rationality of the proposed methodology
- the relevance and quality of the means of implementation
- the resources deployed in relation to the objectives envisaged
(particularly in terms of cost-effectiveness),
- the impact and dissemination of the results envisaged
- the participation of as many Member States as possible
(geographical coverage)
- the innovative nature of the action or project
The relative importance of the various award criteria in the overall

assessment of the quality of the proposals may be quantified by giving each
criterion a weighting. Using weightings is strongly recommended as it
emphasises the important criteria in the context of the call. These shall be
communicated to potential beneficiaries, thus informing them of which
criterion or criteria will be most important in the evaluation of the proposals.

A set of quality thresholds (e.g. 50 % or 65 % of the maximum possible mark)
for the qualitative evaluation, as well as, where appropriate, for each of the
award criteria can be indicated. Applications falling below those thresholds
shall be rejected.
All criteria must be established in such a way as to ensure the respect of the
proportionality principle, given the value of the grant, its duration, its
implementing conditions etc., so that calls succeed in selecting the best
proposals with regard to the objectives pursued without unnecessarily
deterring applicants through unjustified requirements.
Make a distinction about your evaluation criteria
To evaluate the To evaluate the quality of

APPLICANTS PROPOSALS
EXCLUSION criteria
AWARD criteria
SELECTION criteria
Exclusion, selection and award criteria are used in all procurement and grant
procedures.
The wall illustrated here above symbolises the clear distinction that has to be
drawn in your draft documents and in the evaluation procedure amongst the
evaluation criteria. It is strictly forbidden to lay down the same criteria for
both selection and award purposes.
2.2.1.3 Financing modalities:
The proposal submitted by an applicant has to be supported by sufficient

financial information which allows defining:
- the estimated costs/budget for the implementation of the action

- the sources of funding,
- the maximum amount of the grant to be provided by the EU budget,
- the maximum co-financing rate,
- the forms of grants,
- the eligibility of costs,
- the payment modalities (e.g. linked to reporting requirements);

The budget presented with the application should include all estimated costs
related to the implementation of the action (eligible and ineligible) and (if
foreseen) the lump sums, unit costs and flat rate financing as well as all
expected revenues14 (fully balancing the estimated costs). For this purpose it
is recommended to use the model of the budgetary annex which can be
found on BudgWeb.
The costs are eligible if they comply with the following conditions:
 Actually incurred during the action
 Necessary for the implementation
 Planned in the budget estimate
 Identifiable and verifiable
 Meeting accounting standards
 Reasonable and justified
Eligibility of costs starts (in general) the first day of the month following the
last signature of the grant agreement. In exceptional cases the date for the
eligibility of costs can start earlier:
 with the submission deadline of the call for proposals (if foreseen in
the call and if it can be justified by the applicant),
 even earlier, if such a derogation is mentioned in the basic act (and
announced in the call for proposals)
The same goes for operating grants except for the retroactivity up to the
adoption of the basic act. In any case the earliest date as starting point for
eligibility of costs is then the start of the financial year of the beneficiary.
2.2.1.3.1 Eligibility of VAT

The new Financial Regulation, applicable as from 1 January 2013, provides
for the full eligibility of the cost of VAT when attributable to exempt activities
or activities out of the scope, except activities carried out as a public
authority of a Member State. In other terms, non-deductible VAT is eligible
as expenditure, save for those activities matching the concept of sovereign
powers exercised by Member States.
2.2.1.4 Administrative information:

Applicants should be informed e.g. about the templates
to be used, the required supporting documents and the
submission modalities.
14
Revenues can consist of: EU-grant, own resources, third party contributions, income generated by the action,
contribution in kind (if foreseen)

You should also specify:
- The possibilities for submitting applications: by post (postmark), or by

courier service (date of the deposit slip) or delivered in person (receipt). All
three options should be provided.
- The rules on contacts during the procedure (e.g. for questions and answers
via a functional mailbox or a dedicated website).
- The procurement rules for beneficiaries which may need to buy goods or
services for the implementation of the action: Up to and equal to EUR 60 000
the rule is best value for money and no conflict of interest. Above EUR 60 000
the RAO can impose additional rules e.g. of the Financial Regulation.
No subcontracting of "core tasks" is allowed.
- Other supporting documents required and templates to be used e.g. for the
technical and financial reports or the declaration on honour for eligibility,
selection and exclusion criteria.
Templates for calls for proposals, grant application forms and budgetary
annex
The standard template for calls for proposals proposed by DG BUDG is

tailored to grants for actions or/and operating grants under direct
management. It is to be considered as a working basis which must be
adapted to the specific aspects of the programme concerned. It can be used
for one or two stages procedures.
The grant application form and the budgetary annex have to be adapted to
the specificities announced in the call for proposals.
The model templates proposed by DG

BUDG are available in all languages on
BudgWeb15.
15
https://myintracomm.ec.europa.eu/budgweb/en/imp/grants/form-grant/Documents/grant-application-form-
monobeneficiary-en.doc

2.2.2 Legal commitment (grant agreement / grant decision)
2.2.2.1 Mono-beneficiary and multi-beneficiary grants:
Mono-beneficiary:
We have only one entity signing the GA or

being notified the GD. The beneficiary takes
the whole responsibility for the
implementation of the action towards the
Commission and is subject to all rights and
obligations.
Multi-beneficiary:
In this case we have several

entities being responsible for
the implementation of the
project. This approach has
several advantages such as
sharing the operational and
financial risks.
As regards the financial

liability there are 3 options:
 All beneficiaries are jointly and severally liable up to the value of the
contribution that the beneficiary held liable is entitled to receive.
 The financial responsibility of each beneficiary shall be limited to its
own debt (share of the grant), including any amount unduly paid by the
Commission as a contribution towards the costs incurred by the
affiliated entities.
 The beneficiaries shall be jointly and severally liable for any amount
due to the Commission by any one of them which could not be
honoured, up to the maximum amount for the grant.
As regards the signature of the GA there are 2 options:

- One co-beneficiary (usually, but not necessarily the "coordinator"16 or
"consortium leader") receives mandates from the others ("power of attorney")
and it is only him signing the grant agreement with the Commission. All co-
beneficiaries remain responsible for the implementation;
- All co-beneficiaries (not only the nominated coordinator) sign the GA.
As regards payments you have the choice:
Under both options it is possible to make payments only to the coordinator

or to each co-beneficiary (for their respective share).
The latter is more transparent, but implies more work for our services (The
need to create LEF/BAF17 for each co-beneficiary and to split payments
according to their share!).
STRUCTURE
The model grant agreements recommended by DG BUDG and those used by
most DGs follow the same structure:
1. Special conditions
2. General conditions
3. Project description (proposal)
4. Budgetary Annex
5. Other annexes where applicable
All documents in the grant agreement including the annexes are
contractually binding. In case of discrepancy among the different documents,
the special conditions prevail over the general conditions. The above two
prevail over the other documents/annexes.
Special conditions: they contain the elements which are specific to each
project such as the identification of the beneficiary of the grant, the amount
of the grant, the project duration and the payment schedule.
General conditions: they contain a standard set of provisions applicable to all

our grants and they should NOT be altered. Examples are payment time
limits and general rights and obligations of the parties such as legal and
administrative provisions (including applicable law in case of disputes) and
financial provisions (including checks, audits and evaluation).
16
If several beneficiaries are involved in one particular grant, one of them may have the responsibility of
coordinating the action. As coordinator, this beneficiary will become the contact point between the other
beneficiaries and the Commission service
17
LEF = Legal Entity File / BAF = Bank Account File

How and when to fill in a model grant
agreement?
You have to modify the model twice:

First, when you're preparing your call, you will
make your choices for example concerning the
payment arrangements or the reporting
requirements. The agreement models provided
on BudgWeb contain internal instructions for
authorising officers in the footnotes.
Secondly, once your procedure has successfully
come to an end and the award decision is made,
you will have to fill in the details for each project
to be financed.
CHOOSE THE RIGHT ONE

Step-by-step guide for choosing the right model:
Step 1: Mono-beneficiary or multiple beneficiaries (See point 2.2.2.1)
Step 2: Action grant or operating grant (See point 1.3.1)
Step 3: Grant Agreement = GA (signed by both parties) or
Grant Decision = GD (signed only by the Commission)
(See point 2.2.2.2)
Or: Framework Partnership Agreement and specific agreements
(This is very similar to framework contracts in procurement)
(See point 2.2.2.3)
Model agreements on BudgWeb are available for all types of the above
mentioned agreements and need to be adjusted (along the instructions in the
footnotes) to the specificities of your grant.
2.2.2.2 Grant agreement (GA) / grant decision (GD)

The structure of each of these legal commitments differs:
- Grant agreement (GA): Specific conditions + General conditions
+ Annexes (the proposal, forms)
- Grant decision (GD): Motivation + Conditions
+ Annexes (general conditions, forms)
To determine the instrument to be used, the following elements shall be
taken into account18:
(a) Location of the beneficiary, within or outside the Union;
(b) Complexity and standardisation of the content of the actions or work
programmes funded.
18
Article 174 RAP (Rules of Application)

GA is signed by both parties (Commission and
beneficiary) and is the most common form of the
legal commitment.
An agreement is suitable for all types of

beneficiaries, a decision is only binding within
the EU (28 Member States).
GD is only signed by the Commission19. A Decision

is a simplified procedure which saves time and
resources and is generally more suitable for small
standardised grants.
2.2.2.3 Framework partnership agreement (FPA)

and specific agreements
A FPA is concluded as part of a long-term cooperation between the
Commission and the partner with the aim to contribute to the objectives of a
policy field in the EU. It defines the general rights and obligations of the
parties in implementing their partnership along an annual action programme.
For the purposes

of implementing
the partnership,
the Commission
may award to the
partner specific
grants for an
action or specific
operating grants.
Plans to conclude framework partnerships in a given year must also be

included in the year's work programme, with the required information
concerning the justification for conducting work in the form of a partnership,
concerning the selection criteria for partners and the justification for
monopoly positions, where applicable, as well as any plans regarding specific
grants to be awarded for the year in question.
The provisions of the FPA shall apply to any specific grant awarded for
implementation of the partner-ship and to the respective specific grant
agreements concluded between the parties.
19
The decision of the RAO is sent to the beneficiary by registered mail with acknowledgement of receipt, the
date of the receipts being the starting date of the grant

2.2.2.4 Third parties and subcontracting
The Financial Regulation mentions 3 types of third parties which can be

involved in the implementation of the action and for which the costs can be
considered as being eligible, provided that the conditions were announced in
the call documents:
a) Subcontractors: Not limited in percentage of total costs, but "core tasks"

should not be subcontracted.
b) Third parties receiving financial support20 (scholarships, support paid to

persons most in need). This is often called "grants in cascade".
c) The affiliated entities to a beneficiary
Type 1: Where several entities satisfy the criteria for being awarded a grant
and together form one entity, that entity may be treated as the sole
beneficiary, including where the entity is specifically established for the
purpose of implementing the action to be financed by the grant. This is also
known as "European Economic Interest Grouping (EEIG)": e.g. companies in
different countries which do business together and can take part in EU
programmes.
Type 2: Entities that satisfy the eligibility criteria and that do not fall within
one of the situations of exclusion and that have a link with the beneficiary, in
particular a legal or capital (= structural) link, which is neither limited to the
action nor established for the sole purpose of its implementation.
This is usually the case for "mother and daughter companies" or for big
companies / NGOs with "local branches in different countries" (e.g. medicines
sans frontiers in BE, FR etc.). This concept helps to simplify the management
of grants for groupings and networks and allows for recognition of costs
incurred by affiliated entities as eligible (if foreseen in the call and if the
entities are identified in the grant agreement).
Affiliated entities of a (co-)beneficiary can also be allowed in multi-

beneficiary grants.
The main difference between beneficiaries and subcontractors or third

parties is that only the beneficiaries are fully responsible towards the
Commission for the implementation of the action, whereas we have no
contractual relation with third parties or subcontractors which the beneficiary
involves in the implementation.
20
Please note that the maximum amount paid to a third party may not exceed EUR 60 000 unless the financial
support is the primary aim of the EU grant (e.g. financial support for the development of SMEs)

2.3 Pre-financing guarantee
When preparing a call for proposals and during the evaluation phase (e.g.
following the analysis of the financial capacity of an applicant) the possibility
of requesting a pre-financing guarantee has to be taken into account.
The purpose of this guarantee is to make a bank or a financial institution, a

third party or the other beneficiaries stand as irrevocable collateral security
for, or first-call guarantor of the grant beneficiary's obligations.
Since the entry into force of the new Financial Regulation21 pre-financing
guaranties are forbidden for agreements ≤ € 60 000 (low value grants).
However, in order to limit the financial risks

connected with the payment of pre-
financing, the authorising officer
responsible may, on the basis of a risk
assessment require the beneficiary to lodge
a guarantee in advance, for up to the same
amount as the pre-financing, except for
low value grants, or split the payment into
several instalments.
You should also keep in mind the

administrative burden for managing
guarantees (ABAC registration, safe
Guarantee = money
storage, release of the guarantee).
Once you have received
a guarantee, you need to store it
in a secure place.
The guarantee may be replaced by a joint and several guarantee provided by

a third party or by a joint guarantee of the beneficiaries of an action who are
parties to the same grant agreement.
The guarantee shall be released as the pre-financing is gradually cleared
against interim payments or payments of balances to the beneficiary, in
accordance with the conditions laid down in the grant agreement.
21
Article 134 FR / article 206 RAP

3 Publicity, transparency and contacts
3.1 Publicity & transparency
Ex-ante publicity - Article 189.2 RAP :

Calls for proposals shall be published on the internet site of the Union
institutions and in addition to publication on the internet site by any other
appropriate means, including the Official Journal of the European Union,
where it is necessary to provide additional publicity among potential
beneficiaries. They may be published as from the adoption of the financing
decision referred to in Article 84 of the Financial Regulation, including during
the year preceding budget implementation. Any modification of the content
of the calls for proposals shall be subject to publication under the same
conditions as those for the calls for proposals.
Publicity for the WP of year N on the EUROPA-WEBSITE has to be done by

31.03.N.
The means to be used for the publicity of the work programme (Europa
website only, Europa website and DG website or even in the Official Journal)
may vary according to the assessment of the RAO.
The publication of the call documents can be done on the DG's website only,
just make sure that the published call for proposals indicates clearly where
the call documents are/will be published.
Publicity in the Official Journal (OJ):

Your DG's internal instructions will tell you if to send and who can send the
call for proposals for publication on behalf of the RAO. You can also publish
corrigenda or addenda as long as the deadline for submission of applications
has not passed (if necessary, you can extend the deadline).

Important information provided in the call for proposals is where interested
applicants can find or ask for the call documents. It is best practice to
provide a link to your DG's internet page dedicated to calls for proposals,
where they will find all the documents for download.
Translation requirement for call documents
Even though it is often the case that call documents are from the outset
published only in a few languages (e.g. the working languages of the
Commission or the language(s) of the country / countries most concerned),
we have the obligation to provide our documents (upon request) in all (24) EU
languages.
You are therefore strongly advised to
contact DG DGT well in advance to
agree on the arrangements to provide
requested language versions within a
reasonable period of time (of e.g. 5
working days).
Model templates of call documents are available in all official languages on
BudgWeb (Section Implementation/Grants).
Other publicity:
You can foresee additional publicity in newspapers and other appropriate
media, always bearing in mind the principles of equal treatment and non-
discrimination.
EX-post publicity:
According to article 21 RAP, the information on recipients of Union’s funds
awarded under direct management shall be published by 30 June n+1 at the
latest. This is done by DG BUDG via the Financial Transparency System (FTS)
for the Commission and executive agencies.
It is a web
engine allowing
search of the
beneficiaries of
EU funds.
Data made
available in the
FTS is retrieved
from ABAC data.

Mandatory information to be provided is:
(a) the name of the recipient;
(b) the locality of the recipient;
(c) the amount awarded;
(d) the nature and purpose of the measure.
For the purpose of point (b) the term ‘locality’ shall mean:
(i) the address of the recipient when the latter is a "legal" person;
(ii) the Region on NUTS 2 level when the recipient is a "natural" person.
As far as personal data referring to natural persons are concerned, the

information published shall be removed two years after the end of the
financial year in which the funds were awarded. The same shall apply to
personal data referring to legal persons for whom the official title identifies
one or more natural persons.
Exceptions to publication: Scholarships and other direct support paid to

persons most in need.
If a beneficiary considers that there are risks of threat to rights and freedom
of individuals or harm of commercial interests, his opposition must be
expressed when the application is submitted.
3.2 Access to call documents

Transparency, equal treatment
WHAT? All call documents (call for proposals, draft grant agreement / grant
decision, budgetary annex, model templates for the technical and financial
reports, the "declaration on honour" etc.) plus any helpful background
documentation (like preparatory study) if it places the applicants on an equal
footing.
HOW? Via Internet for download or by e-mail to interested applicants -

depending on the modalities announced in the call.
WHEN? If not available for download, within reasonable time of receipt of the
request (around 5 working days).

3.3 Contacts & confidentiality
Contacts between the RAO and the applicants are strictly limited to the
following circumstances22:
Before submission deadline After submission deadline only on the

on the initiative of… responsible AO's initiative
Responsible Applicant: Request for additional Request for

authorising clarify nature / information in relation clarification or
officer: error, provisions / to the exclusion and correction of an
inaccuracy in the interpretation selection criteria. obvious clerical
call documents. of call error.
documents.
Any contact should be in writing only; otherwise a

note for the file should be drafted for each case.
Additional information provided at the request of
applicants, or on the initiative of the RAO, should be
sent simultaneously to all applicants.
Don't answer questions on the phone!
Be polite but insist on receiving the question in

writing and replying the same way.
Best practice: Use the internet website (where the

call documents were published) or a functional
mailbox.
22
FR article 96 on "good administration"; FR article 133 / RAP art. 204.3

4 AWARD STEP BY STEP:
The RAO is responsible for the award stage of the grant procedure. He/she is
entrusted by his/her institution with the powers to exercise the role of RAO.
The sequence of steps will be as specified below (except for framework
partnership agreements where the budgetary commitment is needed only
before signing the specific grant agreements). But, above all, do not forget
the preparatory step of the opening and evaluation of applications.
4.1 Opening and evaluation
Principle of transparency and equal treatment:
Contrary to procurement procedures, there is no need to nominate an

opening committee. Only the nomination of an evaluation committee is
mandatory.
The RAO nominates at least 3 persons to the evaluation committee of which

1 person must be different from the organisational cell. This latter person
cannot have a direct hierarchical link to the RAO nominating the committee
members (exceptions to this rule exist for isolated entities e.g. EU
delegations and representations). The aim of this provision is to ensure the
neutrality, objectivity and maximum impartiality of the committee.
Members of the committee are appointed in writing and must sign a

declaration on honour of absence of conflict of interests and of
confidentiality. Models for the appointment and the declaration are available
on the model grant agreements & other model
documents page on BudgWeb.
The evaluation committee may be assisted by

external experts which (except in RTD) cannot
be members of the evaluation committee and
which do not sign the committee's report. These
experts must also sign a declaration of absence
of conflict of interest.
Who can be a member?

Statutory staff (Officials, temporary agents and contract agents) and ENDs
(detached national experts) can be members, but no interim staff.
Members can be nominated also from other EU institutions or bodies.

What are important issues for RAOs when appointing members?
To ensure that the right competences are present (policy area, scientific field,
financial expertise etc.), that all members understand all evaluation criteria
the same way, that they realise the importance of informing the RAO of any
problem (especially for conflict of interest) and that the members must come
to a collegial decision (by consensus23) to be expressed in the evaluation
report.
The RAO sets up a structure and organisation for the opening of applications
and for their objective and impartial evaluation. This structure must comply
with the principles of transparency, equal treatment and proportionality.
The RAO should ensure that the committee members have a clear
understanding of the four types of criteria determining grant awards
(eligibility, exclusion, selection and award criteria which must have been
clearly defined and differentiated). The criteria and their purpose should not
be confused as this may lead to disputes, even to a possible cancellation of
the call. That’s why it’s important to have defined good quality thresholds.
The order of assessment of the criteria is left to the appreciation of the RAO
and could vary depending on the complexity of the programme, the number
of applications, the nature of the beneficiaries, etc.
The Committee decides how they’ll work (Working method), if not already
imposed by the RAO.
4.1.1 Tasks of the evaluation committee
If no opening committee was

nominated, the evaluation committee
members will be in charge of the
opening before starting their proper
evaluation tasks:
- Check the compliance of the

applications with the submission
rules24 (deadline respected and
confidentiality ensured i.e. envelopes
closed).
- Draft a record including a list of compliant and non-compliant applications.
23
A voting system is therefore not considered appropriate
24
The non-compliance with those requirements will prevent further review of the applications as they will be
considered inadmissible

As the deadline for applications is the submission date – and not the arrival
date at the entity in charge – before convening the committee, leave time for
all the applications to reach the contracting authority, otherwise you might
end up organising several opening sessions and records of these meetings.
Evaluation committee:
Evaluates and ranks the proposals;
Requests missing information in
relation to the exclusion and selection
criteria;
Notifies the RAO of obvious clerical
errors;
Requests justification, clarification and
/ or correction of errors in relation to
the award criteria25;
Drafts the evaluation report containing
the detailed evaluation of each
proposal, the conclusions and the
proposed beneficiaries for the award;
Who evaluates?
Every member of the evaluation committee evaluates the proposals and signs
the evaluation report.
Evaluation of all the criteria
The RAO can decide that the exclusion and selection criteria will be evaluated
by other appropriate means than the evaluation committee. A record of the
e77valuation of exclusion and selection criteria will then have to be produced
and included in the evaluation committee’s report
showing its ranking of the best proposals based on
the award criteria.
An evaluation grid often proves helpful.
25
To prevent rejection of proposals on purely formal grounds (clerical errors) in accordance with the good
administration principle, contacts with applicants are possible during the evaluation and even
COMPULSORY in case of obvious clerical errors including missing documents. The RAO has to report on
the absence of such contacts!
Contacts have to take place in writing and new information should not lead to substantial changes to the
proposal. Only allow for limited time to response.

Criteria published = criteria applied
If you are a member of an evaluation committee, you must apply all the
criteria as published in the call for proposals, with no confusion between
selection and award criteria. The weighting of the award criteria and the
ranking formula cannot be modified or adjusted.
4.1.2 Evaluation report: a public document
The evaluation report contains the comments and

recommendations of the evaluation committee, and is intended to
help the RAO make a decision.
This report is a formal document containing

the final opinion of the committee. It should
not consist of nor include "internal
minutes" of the discussions that lead to it
or the sum of individual evaluations.
The report is the source of the information
ultimately given by the RAO to the candidates
and tenderers.
The evaluation report is an administrative

document accessible to the public after the procedure, either in full or
in part (protection of personal data).
A model report is available on the "Model grant agreements and

other models" page on BudgWeb26.
4.1.2.1 Adjustments and corrections

As a result of the evaluation, the evaluation committee may recommend the
authorising officer to suggest the applicants to make some (non-substantial)
adjustments to its application. Adjustments only concern minor, ancillary
elements which do not call into question the evaluation of the proposal or
change substantially the proposal of the applicant. The applicant(s) may
refuse to adjust the application. This is a possibility for them, not an
obligation.
Timing: After the evaluation report and before the award decision
Examples of adjustment: Reduce the cost of a marginal item of expense that
the committee considered too expensive.
26
http://myintracomm.ec.testa.eu/budgweb/EN/imp/grants/Pages/grants-agreement.aspx

Example of what is not an adjustment: Ask the beneficiary to increase co-
financing, take out or include some activities in the project.
The Authorising Officer and the committee may also request corrections to
errors. These need to be done by the applicant and cannot be refused.
E.g. a beneficiary forgot to put in the budget the costs of audit certificates
when these are required.
4.2 Award decision
Independent decision taken in compliance with the principles of

TRANSPARENCY, EQUAL TREATMENT & SOUND FINANCIAL MANAGEMENT
The RAO makes the award decision.
The RAO may also decide to abandon or cancel

the procedure.
The RAO can deviate from the evaluation

committee’s proposal, but he has to justify this.
The award process must be consistent with the

procedure (what was announced in the call for
proposals). The RAO cannot award a grant on the
basis of incorrect elements.
To help in their role as guardians of the rules,

prior to making their decision, RAO can - and in some cases, depending on
the instructions of the Director General27, must - ask the advisory bodies set
up in the DG/service for their opinion on the legality of the procedure. This
role is generally the responsibility of the central finance unit or an internal
collegiate body.
The award decision must at least contain the following elements:
(a) the subject and the overall amount of the decision;
27
Director in executive agencies

(b) the name of the successful applicants, the title of the actions, the
amounts accepted and the reasons for that choice, including where it is
inconsistent with the opinion of the evaluation committee;
(c) the names of any applicants rejected and the reasons for that rejection.
Information of applicants:
- To notify the RAO's reasons as per the

award decision and the observations
included in the evaluation report.
- To allow applicants to ask for additional
information about the relative merits of
the successful proposals.
- To ask, if judged appropriate by the RAO,
for documents in support of the successful
applicants' declaration on honour
concerning the exclusion criteria for grants
> EUR 60 000.
- To bring any relevant information to the
RAO's attention that might persuade him
to change his decision (legal irregularity, Applicants are informed
disregard of an administrative or technical simultaneously in writing
piece of information in a tender, etc.) and
therefore not to sign the grant agreement.
Rejected applicants shall be informed as soon as possible of the outcome of

the evaluation of their application (including the justification of the decision)
and in any case within 15 calendar days after information has been sent to
the successful applicants.

4.3 Commitments
4.3.1 Budgetary commitment
According to the single signatory rule, the

budgetary commitment (in ABAC) and the
legal commitment are adopted by the same
RAO.
The golden rule!!!

The RAO must ALWAYS make the budgetary
Budgetary & legal commitments
commitment before signing the agreement.
always go hand in hand
(Except for framework partnership
agreements)
4.3.2 Legal commitment
The RAO alone is entitled to enter into legal commitments binding for the
institution. Up to the point of signature by both parties, the RAO is also
entitled to cancel the award procedure.
Implementation of an action starts once that the

grant agreement has been signed by both
parties!
The agreement can be sent with the letter of

information to the successful applicant.
Recommendation:
Send the successful beneficiaries two copies of
the agreement initialled on each page but not yet
signed by the RAO.
A successful beneficiary refuses to sign the

agreement:
In such a case you can offer a grant to the first
beneficiary on the "reserve list", if such a list
could be established (following sufficient number of proposals reaching the
required quality threshold which could however not been selected within the
maximum amount available for the call).

5 Implementation phase
5.1 Payments
Choosing the payment arrangements:

When drafting the agreement (see also point 2.2.1.3 above), you have chosen
the payment arrangements best suited to:
 the estimated value of the agreement (very low-value = single payment
e.g. for scholarships)
 the schedule of the deliverables/reports during the implementation of the
grant phases linked to different types of payments
Payment types:
Single payment = a payment of the entire amount due once the action is
completed: It is well suited for simple standardised grants with low amounts
(e.g. simplified forms of grants with lump sums)
Pre-financing payment = it aims at providing the beneficiary with a float in
order for him to be able to start carrying out the supported action or work
programme: Until the clearing of the pre-financing (at interim or final
payments) the Commission / the institution remains the owner of the money
but there is no interest accrued since the entry into force of the new FR by
1.1.2013. Depending on the risk assessment of the RAO there can be one or
more pre-financing payments.
Interim payment = a split in several instalments over the period of
implementation of the action: There can be one or more interim payments
fixed in the grant agreements which are linked to the progress of the action.
An interim payment is made only after verification that the conditions of the
grant have been fulfilled and that costs are actually eligible. The rhythm of
payments is to be aligned to the duration of the project.
Final payment = payment of the balance: It is recommended to keep a
minimum amount for the payment of the balance to facilitate the task of
receiving all required reports and being able to close the files, even in case
the initial budget was overestimated. There can only be one final payment
and it closes the file. In cases where the amount of the contribution payable
stays below the payments already effected (pre-financing(s) and interim
payment(s) together), a recovery order has to be made and closes the file.

Basis of verification:
The agreement sets the arrangements

for verifying the implementation of the
action. Verification of progress is done
on the basis of the analysis of:
 technical reports
 payment requests / cost claims
 monitoring and expenditure verification reports
 audit certificates on financial statements
Stages of verification and payment - the "four eyes" principle:
"Certified correct" = the action has taken place as foreseen.

To certify that this is the case, the project manager (generally the operational
initiator) approves the report / payment request with the apposition of the
"certified correct".
"Passed for payment" = the amount of the invoice corresponds to the amount
due. Perhaps your DG has a checklist to help you to check this. To certify that
this is the case, the RAO or a person appointed for that purpose, will
"validate" the "passed for payment" by approving the transaction in ABAC.
Corrected cost claim:

If the amount claimed by the beneficiary is not correct, the RAO may either
request an adjusted payment request or the RAO may directly adjust the
payment without asking for an adjusted payment request from the
beneficiary (in case of corrections downwards).
In any case we inform the beneficiary about the corrections.
Audit certificates: A certificate on the financial statements of the action or

the work programme and underlying accounts, produced by an approved
external auditor or in case of public bodies, by a "competent and
independent public officer, may be demanded by the RAO in support of any

payment, on the basis of a risk assessment. The certificate shall be attached
to the payment request. It shall certify, in accordance with a "methodology
approved by the RAO and on the basis of agreed-upon procedures compliant
with international standards, that the costs declared by the beneficiary in the
financial statements on which the payment request is based are real,
accurately recorded and eligible in accordance with the grant agreement or
decision28. Above certain thresholds, this document is compulsory: for action
grants ≥ 750 000 EUR, if total of
contribution to be paid is higher than
325 000 EUR and for operating
grants ≥ 100 000 EUR.
Exceptions: Not possible for lump
sums and flat rate financing.
The RAO may also waive the
obligation to provide such certificates
on the financial statements and
underlying accounts in the case of
public bodies, international
organisations and for beneficiaries of
grants in connection with humanitarian aid, civil protection emergency
operations and the management of crisis situations, save in respect of
payments of balances.
Time to pay = TTP

The time allowed for making payments shall
be understood as including validation,
authorisation and payment of expenditure.
This means that we have single periods for
both report approval (financial and
operational) and the preparation of the
payment – there is no separation any longer
between the time spent for approving the
reports and the time spent for making the
payment (like before 1.1.2013).
Payments shall be made within:

(a) 90 calendar days for grant agreements and decisions involving actions
which are particularly complex to evaluate and for which payment depends
on the approval of a report or a certificate;
(b) 60 calendar days for all other grant agreements and decisions for which
payment depends on the approval of a report or a certificate;
28
Article 135 FR, article 207.3 RAP

(c) 30 calendar days for all other grant agreements and decisions.
We have an internal targeted deadline of 20 days for the first pre-financing29
Payment of late interest:

On expiry of the time limits, the creditor shall be entitled to payment of late
interest. For amounts of interest above 200 EUR we have to pay automatically
(ABAC calculates late interests), below 200 EUR we have to pay only upon a
demand submitted by the beneficiary within two months of receiving late
payment.
5.2 Implementation problems
A number of problems may arise in the course of implementing a grant. Most

of these are already covered by the general conditions in all model
agreements and do not
therefore need to be
spelled out again case by
case. It is best never to
touch the general
conditions without
discussing it with BUDG.D.2
first, as they contain
provisions that safeguard
the interests of both
parties. If need be though,
unit BUDG.D.2, as guardian
of contracts adopted by the
Commission, can be contacted for proposed changes. The Vade-mecum on
Grants provides additional information and advice on possible reactions to
problems connected with the implementation of grants.
A grant agreement or decision can be amended (=modified) during the

implementation of the action/work programme.
There is a limit to what extent the RAO can accept amendments.
He/she will never accept changes that question the award decision taken
about the concerned grant agreement / decision.
29
Commission Communication SEC (2009) 477 on the "Streamlining of financial rules and accelerating budget
implementation to help economic recovery"

The request for an amendment should not question the principles of
transparency & equal treatment amongst applicants and amongst
beneficiaries.
Any amendment must be signed before the end of the grant agreement /
decision.
Agreements can also be suspended or terminated.
In case of suspension/termination it is important to determine the

circumstances for such a decision and the effects on the implementation of
the action. Whatever the reason, the letter informing of the decision of the
RAO must contain information on means of redress30: How, where, when the
beneficiary can defend its case and challenge the decision of the RAO
5.3 The Early Warning System
The EWS is an internal alert tool containing information on third parties likely
to represent a threat for the EU financial interests and reputation. EWS
warnings are divided in two categories: "verification warnings"
enabling the responsible authorising officer to make verifications
and "exclusion warnings" where a third party is excluded in
accordance with the grounds of exclusion provided for in the
Financial Regulation. The warnings are inserted with a red flag in
the Legal Entity File (LEF) visible in ABAC.
The EWS is linked to the Central Exclusion Database (CED)

containing all the entities which are under an exclusion situation.
Access to the EWS is restricted to the Commission and the
executive agencies. Other institutions and bodies do not have
access to the EWS but only to the CED. The EWS/CED must be
consulted before awarding a grant agreement.
More information on the EWS and CED is available on BudgWeb.
5.4 Filing and controls
The call documents, the evaluation report and award

decision, financial files and all documents relating to
the implementation and monitoring of the grant
agreement as well as correspondence with the
30
FR 135 – RAP 208 + General conditions of agreements / decisions
Good Administration (Art. 96 FR) – Means of Redress (Art. 97 FR)

beneficiaries must be kept and made accessible for
possible inspection by the Court of Auditors or for
internal control and audits (usually for a period of 10
years).
Regulatory requirements for the beneficiaries to

keep documents related to the grants, meaning the
period for the right of checks and controls as from
payment of the balance:
- 5 years in general
- 3 years for low value grants, without prejudice to
on-going audits, appeals, litigation or pursuit of
claims.
More details are provided in the Grants Vade-mecum and on BudgWeb.

6 Reference legislation
Financial Regulation (FR):

Regulation (EU, Euratom) No 966/2012 of the European Parliament and of the
Council on the financial rules applicable to the general budget of the Union
and repealing Council Regulation (EC, Euratom) No 1605/2002 (OJ L 298,
26.10.2012, p.1)
Rules of application (RAP):

Commission Delegated Regulation (EU) of 29.10.2012 on the rules of
application of Regulation (EU) No 966/2012 of the European Parliament and
of the Council on the financial rules applicable to the general budget of the
Union
Good luck!
Your training team

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GRANTS - BASICS

Participants' course manual

DG BUDG – Central Financial Service

1 Before launching a grant procedure 5

2 Prepare your call 12

3 Publicity, transparency and contacts 28

4 Award step by step 32

Grants participant's manual 2

What are Grants?

Grants are a type of expenditure financed by the EU budget that is managed

Grants fall into two broad categories:

 grants for actions intended to help to achieve an objective that forms

 operating grants that finance the operating expenditure of a body

In the case of grants, we don't receive anything in return as it is the case in

Grants participant's manual 3

The manual includes information on all basic aspects of a grants procedure.

Chapter 3 explains how we respect the principle of transparency via publicity

The reference legislation is provided in Chapter 6.

BudgWeb is the Commission's internal financial website which contains

4 Grants participant's manual

1.1 Procurement or Grant? 5

1.2 Basic principles 6

1.3 Types and forms of grants

1.3.1 Action grants and operating grants 7

1.4 Background information 9

1.4.1 Content of a call for proposals 9

1.1 Procurement or Grant?

As a general rule, the difference between public procurement and grants is

Procurement = buying Grant = support

Grants participant's manual 5

1.2 Basic principles

In grants management, you should pay particular attention to the following

Equal treatment and non-discrimination

6 Grants participant's manual

1.3 Types and forms of grants

 Action grants that finance a project intended to help to achieve an

Examples of action grants:

Scholarships ("Erasmus+"), research projects (under

Grants participant's manual 7

College of Europe (Bruges and Warsaw), EuroNews, European committee for

1.3.2 There are five forms of grants4:

Grants may take any of the following forms:

Lump sums: Flat rates: Unit costs:

8 Grants participant's manual

1.4 Background information

1.4.1 Content of a call for proposals

The European Commission prepares a "call for proposals" when it issues a

1.4.2 Pre-conditions & legal framework

Grants participant's manual 9

Budget line and budget programming:

Make sure that the necessary funds for

A work programme (= WP which can be multi-annual) and an annual

Administrative expenditure covering the running

10 Grants participant's manual

The Responsible Authorising Officer – RAO

The decisions concerning the procedure to organise

The project manager (often OIA)

The financial officer (often FIA)

Grants participant's manual 11

2.1 Prepare your work schedule & 1 step or 2 steps procedure 13

2.1.1 Prepare your work schedule 13

2.2 Draft your call documents 14

2.2.1 Content of a call for proposals 15