projektfinanzen die programmregeln · content 3 flc seminar, bremen | 21 november 2017 1. hierarchy...

Projektfinanzen – Die Programmregeln

First Level Control Seminar Bremen | 21 November 2017 Dana Hennings, Václav Kaplan, Managing Authority/Joint Secretariat

Content

FLC Seminar, Bremen | 21 November 2017 3

1. Hierarchy of rules

2. General eligibility rules

3. Budget lines

4. Activities outside the EU & Programme area

5. State aid

6. Project changes

7. Final remarks

Hierarchy of rules

5 Hierarchy of rules (Article 18(3) of Regulation (EU) No 1299/2013)

Programme Manual

General eligibility rules

General principles

• All costs must belong to a project partner NO sub-partners NO COST SHARING

• All cost must follow the real costs principle (exceptions: unpaid voluntary work, simplified cost options, depreciation)

• Reimbursement principle NO advance payment for ERDF & Norwegian funds

Eligibility periods

• Contracting phase (min. 3 months) project costs

• Implementation phase (max. 36 months) fully eligible

• Closure phase (3 months) limited eligibility

• Post-project phase no costs eligible

Use of Euro and exchange rate

• Progress report: All expenditure in EUR

• Partner reports:

EUR = National currency EUR ≠ National currency

Entire report in EUR For entire report: Exchange rate published by EC of month of partner report submission to FLC

ADDITIONAL SLIDE

Budget lines

Budget lines P

t BL1 - Staff

BL2 - Office & administration

BL3 - Travel & Accommodation

BL4 - External expertise & services

BL5 - Equipment

(BL6 - Infrastructure & works)

(BL7 – Project specific activities)

Budget lines

FLC Seminar, Bremen | 21 November 2017

1. Full-time and part-time staff

2. Unpaid voluntary work

BL1 - Staff: Types

Employed by partner organisation

Formally engaged in project activities

100% of the employee‘s

working time is spend for project

< 100% of the employee‘s

working time is spend for project

Full time Part-time

BL1 - Staff: Full-time and part-time

Gross employment costs

Fixed in employment document or by law

Non-recoverable

Examples:

Salary

Other costs directly linked to the salary

BL1 - Staff: Eligible costs

Full time Part-time

Employment document

Job description

Documentation of gross employment costs

Payment proof

Staff costs tool

+ method specific documents

BL1 - Staff: Documentation

Fixed percentage of time worked per month

Percentage fixed in employment document in advance

No timesheet needed

Simple calculation

Over- or undercompensation possible

BL1 - Staff: Calculation options

Part-time

Calculated with a yearly hourly rate

Annual gross employment costs of previous 12 months divided by 1,720 hours

Only need to calculate it once

Over- or undercompensation possible

Timesheet needed

Part-time

Calculated with a monthly hourly rate

Monthly gross employment costs of actual month divided by monthly working time set in employment contract

Timesheet needed

Closest, but not equal to real costs

Vacation and sick leave are not covered

Part-time

Calculated with a contracted hourly rate

Hourly rate set in the employment contract multiplied with actual working hours

Can only be used by staff that is paid on hourly rate basis

Timesheet needed

Vacation and sick leave not covered

Part-time

Fixed % Annual hourly rate

Contracted hourly rate

Monthly hourly rate

Fixed working hours

Flexible working hours

Part-time

Do not mix the calculation methods!

Documentation

• Signed agreement with voluntary worker

• Signed timesheets

• Staff cost tool

Calculation

• Hourly rate Max. hourly rate for equivalent work

• Limit per partner Unpaid voluntary work < Own contribution

• Other essential expenditure (e.g. travel costs, material) can be reported in other budget lines

BL1 - Staff: Unpaid voluntary work

flat rate of BL1 staff costs

Automatic calculation

Costs covered under BL2 cannot be reported under any other budget line!

BL2 - Office & administration

Project employees

belongs to BL3

Travel (e.g. tickets, fuel, car mileage, toll, parking fees)

Accommodation

Daily allowances

If not covered by allowances:

• Meals (other than catering!)

• Visa

External experts/speakers/…

belongs to BL4

Travel and accommodation

Active role !

24 FLC Seminar, Bremen | 21 November 2017

Every travel must be project related !!!

Reporting documents

• Invoices or equivalent accounting documents of travel costs

• Payment proof

• Proof of reimbursement of costs to the employees where

employees made a direct payment for travel

25 FLC Seminar, Bremen | 21 November 2017

Studies/ surveys

Training/ translations

Financial management

Legal/technical consultancy

IT systems & websites

Promotion, communication

Travel of externals

First level control

Basic courses

Services from other partner/own staff

Intellectual property rights

BL4 - External expertise & services

• Office equipment • IT hardware & software • Furniture & fittings • Laboratory equipment • Machines & instruments • Tools or devices • Vehicles • Other

BL5 - Equipment

1. Equipment which is part of an investment

• Clear link to an investment output

• Full costs eligible

2. Other equipment

• Tools/devices to implement other project activities

• Depreciation/rental/leasing costs for period of use

BL5 - Equipment

Investment equipment in the application

BL5 - Equipment

Investment equipment in the application

• Only investment related costs Blocked if no investment outputs planned

• Full costs eligible

• Examples: Works for … site preparation, delivery, handling, installation, renovation

BL6 - Infrastructure & works

• Application: Indicative specification of contracts (sections 6.1, 6.2 and 6.3)

• Partner reports & progress report:

Expenditure for all contracts

Overview of contracts above EU thresholds only

BL4, BL5 and BL6

• Documentation:

Procurement

Contracts and invoices

Proof of delivery

Payment proof

• Only available for projects that applied before submission of application

(BL7 – Project specific activities)

ADDITIONAL SLIDE

Activities outside the EU & Programme area

Do I need prior approval by MA/JS?

• Programme area & EU NO

• Other countries YES

State aid

What is State aid?

• Programme funds = public funds

• Company receives benefit over competitors

• In general: State aid is prohibited

• BUT: State aid instruments allow exceptions

De minimis

General Block Exemption Regulation (GBER)

State aid

What kind of State aid is granted?

• Project partners with State aid relevant activities

Because: advantage over competitors through first-hand knowledge, new customers, new services or new products

Entire partner budget affected

Example: Entire budget is State aid relevant 39

State aid

What kind of State aid is granted?

• Project partners with State aid relevant investments

Because: advantage over competitors through lower investment costs

Budget lines 5 and 6 affected

Example: State aid relevant investments in BL6 41

Example: Only part of the budget is State aid relevant 42

Example: Group of activity marked as State aid relevant 43

State aid

What has to be observed?

• Follow the requirements included in:

Clarification form (e.g. open-access principle)

De minimis declaration and award letter (e.g. max. de minimis available)

Layout of de minimis declaration and award letter 45

State aid

• Follow the requirements included in:

GBER declaration (e.g. general and specific conditions)

ADDITIONAL SLIDE

Layout of GBER declaration and GBER and SME declaration 47

ADDITIONAL SLIDE

State aid

• Accounting: Carefully separate State aid expenditure

Note! Revenues not deducted

• Reporting: Provide details on State aid relevant activities

• State aid budget cannot be exceeded

State aid

What is the role of the first level controller?

• In general to check whether:

State aid relevant activities in line with application form

Other activities are not of economic nature

State aid expenditure correct in accounting system and report

State aid budget of the project partner not exceeded

Extract from first level control report and checklist for the LP FLC

First level control report and checklist/LP

ADDITIONAL SLIDE

State aid

What is the role of the first level controller?

• In case of GBER to check whether:

Specific conditions as laid down in the GBER declaration complied with

Project activities started after the application form was submitted to the MA/JS

ADDITIONAL SLIDE

Project changes

Minor changes: no prior approval

• Budget flexibility on project level

Total budget lines can be exceeded

20% or EUR 40,000 to be observed

• Partner data change

• Always check with your lead partner!

Project changes: Budget flexibility

BL1 BL2 (15%)

BL3 BL4 BL… Total

PP1 200,000

PPn 400,000

Total approved

300,000

(45,000) 200,000 50,000 5,000 600,000

Total reported

360,000 (+60,000 = +20%)

(51,000) (+9,000 = +20%)

101,000 (-109,000)

90,000 (+ 40,000)

5,000 600,000

300,000 200,000 50,000 (45,000) 5,000

Project changes

Major changes: prior approval

• Partner drop-out

• Change of legal status, name, etc.

• Inclusion of reserved partners

• Budget reallocation

• Workplan changes

• Project prolongation

Restrictions

• Minor changes, e.g.

No changes in State aid relevant activities, outputs and/or budgets

No flexibility on partner budget

No flexibility on unit price in BL7

• Major changes, e.g.

State aid budget cannot be exceeded

Only one pure budget reallocation

Final remarks …

Please also consider…

• Retention period

~ 4 years after final payment (exact date from MA/JS )

Stricter rules for State aid

• Originals or in versions “in conformity with the original on commonly accepted data carriers”

• Durability & ownership of (investment) outputs

Projektfinanzen – Die Programmregeln

Dana Hennings & Václav Kaplan

Finance Officer

Managing Authority/Joint Secretariat

Phone +49/381 45 484 5280 & -90

e-mail: name.surname@interreg-baltic.eu

www.interreg-baltic.eu

Interreg Baltic Sea Region believes

in an integrated and prosperous Europe for all

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