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EStIF 4 |2017 287Lessons Learnt from the Closure of the 2007-13 Programming Period

Lessons Learnt from the Closure of the2007-13 Programming Period

Martin Ferry and Stefan Kah*

This article is based on a study for the Committee on Regional Development of the EuropeanParliament. It analyses the closure process for programmes funded under the European Re-gional Development Fund and the Cohesion Fund in 2007-13. Programme closure is oftenseen as a purely technical process. It involves shutting down the operation of a programme,finalising the reporting and recording of results, and ensuring sound financial management.However, closure also plays an important strategic role. Key decisions are taken by pro-gramme authorities at this stage: in the allocation of remaining funds; in securing and rais-ing awareness of achievements and legacies; and, in ensuring a smooth transition to thenext programming period. These decisions are taken in the context of considerable pres-sures: to absorb the maximum funding available; to respond to financial controls and au-dits that often take place around programme closure; to deal with issues arising from theimplementation of specific projects; and, to ensure administrative resources are availableat a time of transition between programme periods. Based on a review of academic and eval-uation evidence, recent research, legislation, EC and Member State policy papers as well asevidence from EU, national and sub-national stakeholders, this article details the regulato-ry provisions, guidance and support provided for closure in 2007-13, and assesses the issuesfaced and responses made by programme authorities, summarised under three headings:absorption, types of intervention and administrative capacity.

I. Introduction

The deadline for the submission of closure documen-tation by Member States (MS) to the European Com-mission (EC) for the 2007-13 programmes fell at theend of March 2017. Thus, it is timely to assess theprocess in order to identify key lessons and insightsand examples of good practice, particularly with aview to the progress of the 2014-20 closure arrange-ments.

Programme closure is often seen as a purely tech-nical process: the fulfilment of legal, regulatory and

bureaucratic requirements at the end of a program-ming period. The formal obligations associated withclosure are important (see Figure 1):– Foremost is the need to ensure that programmes

are fully committed (i.e. that all programme fundsare committed by the managing authority (MA) toprojects, defined in Funding Agreements) andspent (i.e. that expenditure incurred by projects isfully paid), while recognising the tension betweenbeing able to spend for as long as possible and hav-ing enough time to organise closure.

– Settling of the final balance, which clears all pre-ceding expenditure to operations or the recoveryof sums paid in excess by the EC, is the aspect ofclosure emphasised in the Financial Regulation.

– Ensuring legality and regularity of expenditure, asthe EC is required to accept only expenditure im-plemented in compliance with the EU and nation-al rules.

– The process of terminating a programme, consist-ing of the submission to the EC of a ‘closure pack-age’ of documents: an application for payment of

* Martin Ferry is a Senior Research Fellow in the European PoliciesResearch Centre at the University of Strathclyde. He specialises inregional economic development and policy governance in Cen-tral and Eastern Europe (particularly Poland) and the UnitedKingdom. Stefan Kah is a Knowledge Exchange and ResearchFellow in the European Policies Research Centre at the Universityof Strathclyde. He is manager of the IQ-Net network of StructuralFunds programme authorities and specialises in regional policyand Cohesion policy in Alpine countries, particularly in Austria,Slovenia and Switzerland. The views expressed in this article arepersonal.

EStIF 4 |2017288 Lessons Learnt from the Closure of the 2007-13 Programming Period

the final balance, a Final Implementation Reportand a closure declaration. The preparation of thepackage requires contributions by three main pro-gramme management bodies in the MSs: from theMA, Audit Authority (AA) and Certifying Author-ity (CA).

However, there is a danger that closure is perceivedas a formal appendage to the management and im-plementation process, or even as an after-thought. Itis crucial to look beyond the formal components ofclosure to appreciate the integral role it plays in thesuccessful implementationof EuropeanRegionalDe-velopment Fund (ERDF) and Cohesion Fund (CF)programmes. Key strategic decisions are taken byprogramme authorities at this stage in the life of anOP: in the allocation of remaining funds; in securingand raising awareness of programme achievementsand legacies; and, in ensuring a smooth transition tothe next programming period. Moreover, these keydecisions are taken in the context of considerablepressures: to absorb themaximumfundingavailable,to respond to financial controls and audits that often

take place around programme closure, to deal withissues arising from the implementation of specificprojects; and, to ensure that adequate administrativeresources are available at a time of overlap betweenprogramming periods. It is important that lessonslearned from the closure process are fed into plan-ning for future programmes, alongside the results ofmonitoring and evaluation processes. The delayedlaunch of programmes in 2014-20 and the potentialpressure this will place on closure processes at theend of the current period make these lessons partic-ularly pertinent.

For these reasons, closure represents a key stagein the lifecycle of OPs. An assessment of the experi-ences of programme authorities in complying withthe formal requirements for OP closure in 2007-13and, beyond this, an exploration of the factors thatinform the relationship between the closure processand the effective implementation of programmesprovides valuable insights, particularly with a viewto the progress of the 2014-20 closure arrangements.After outlining the timetable for the closure processfor 2007-13 programmes, this article describes an an-

Figure 1: The Chal-lenges of ProgrammeClosure.Source: EPRC.


alytical framework to explore issues around closure,based on analysis of closure processes and experi-ences in the 2000-06 period. The analytical frame-work is then applied to the experience of closure in2007-13. The paper finishes by drawing out key con-clusions and insights for closure of the 2014-20 pro-grammes. The paper is based on a 2017 study carriedout for the REGI Committee in the European Parlia-ment.1 Focussing specifically on programmes fund-ed under the ERDF and CF in 2007-13, research in-volved a combination of desk-based research and in-terviews with the DG REGIO officials and pro-gramme authorities from case study programmes ineight Member States.

II. The Closure Timetable

TheECset out its closure requirements for the2007-13programmes in General Regulation 1083/20062 andin its amendment, regulation 1297/2013.3 In additionto these, the EC adopted closure guidelines on 20March 2013 after a 14-month period of drafting andconsultation.4Anamendedversionwaspublishedon30 April 2015.5 The key dates in the closure processare set out in Table 1 with 31 March 2017 the finaldate for the submission of closure documents.

All Member States kept to the deadline of 31st

March 2017 for submission of closure ‘packages’ toEC (Croatia’s deadline is March 2018). The Commis-

sionhad fivemonths to respond to these submissionsand programme authorities have now received let-ters from the Commission containing feedback ontheir closure packages. Feedback has generally in-volved technical questions, including:– on the amounts reimbursed from the EC and

amounts paid out to beneficiaries (e.g. related todealing with surplus funding, calculation ofVAT);

– some questions seeking further information onFinancial Engineering Instruments (FEI) report-ing;

– questions on indicators;– comments on Final Implementation Reports for

individual Operational Programmes (OPs) etc.

Programme authorities are currently in the processof responding to this feedback.6

III. Analytical Framework

A review of the challenges presented by the 2000-06closure process in different MS contexts, and provi-sions made in response by EC closure guidance for2007-13 highlights key variables that can be used toanalyse the closure experiences of programme au-thorities. Assessments of the process in the 2000-06period from the EC7, the ECA8 and research carriedout as part of the IQ-Net network of programme au-

1 Ferry, M., and Kah, S., Research for REGI Committee – Lessonslearnt from the Closure of the 2007-13 Programming Period(European Parliament, Policy Department for Structural andCohesion Policies, Brussels 2017); available online at (last accessed 4 December2017).

2 Council Regulation (EC) No 1083/2006 of 11 July 2006 layingdown general provisions on the European Regional DevelopmentFund, the European Social Fund and the Cohesion Fund andrepealing Regulation (EC) No 1260/1999, available online at (last accessed 4 December 2017).

3 Regulation (EU) No 1297/2013 of the European Parliament and ofthe Council of 11 December 2013 amending Council Regulation(EC) No 1083/2006 as regards certain provisions relating tofinancial management for certain Member States experiencing orthreatened with serious difficulties with respect to their financialstability, to the decommitment rules for certain Member States,and to the rules on payments of the final balance, availableonline at (last accessed 4 December2017).

4 European Commission (2013), Commission Decision of20.3.2013 on the approval of guidelines on the closure of opera-tional programmes adopted for assistance from the European

Regional Development Fund, the European Social Fund and theCohesion Fund (2007-2013), C(2013) 1573 final, availableonline at (last accessed 4 December 2017).

5 European Commission (2015), ANNEX to the Commission Deci-sion amending Decision C(2013) 1573 on the approval of theguidelines on the closure of operational programmes adopted forassistance from the European Regional Development Fund, theEuropean Social Fund and the Cohesion Fund (2007-2013),C(2015) 2771 final, ANNEX 1, available online at (last accessed 4 December 2017).

6 Michie, R., and Dozhdeva, V., ‘Halfway there? Taking stock ofESIF programme implementation’ [2017] IQ-Net Review Paper41(1), European Policies Research Centre.

7 Von Busch, A., Closure 2007-2013: Changes and Lessons learnedfrom 2000-2006, Modifications to the closure guidelines (seminar,Lisbon 13 May 2014).

8 Dencső, B., ‘The lessons of the financial closure of the 2000-2006period’ (Seminar on the experience gained during the winding upof the programming period 2000-2006, Budapest, 20-21 Septem-ber 2012); available online at (last accessed 4 December2017).


thorities9 highlighted issues faced by programme au-thorities during closure that can be grouped underthree main headings (see Figure 2):– Meeting spending targets. Programme authorities

balanced the aim of ensuring optimal absorptionof the available funds with the need to meet clo-sure deadlines and allow sufficient time for theclosure process to take place. In this context, itshould be noted that in 2008 the EC extended thefinal date of eligibility for the 2000-06 OPs to en-sure the maximum use of all Cohesion Policy (CP)resources from the 2000-06 period.

– Dealing with specific types of project. In many pro-grammes, the main concern was that too manyuncompleted projects would remain at the timeof closure and there was a focus on ensuring thetimely closureof individual projects. Certain typesof projects were seen as potentially most problem-atic. Notably, there was concern that majorprojects (MPs) riskednot being completed on time(e.g. Germany, Greece). Difficulties emerged be-cause of unforeseen delays or weaknesses in esti-mating the time needed for administering largeand complex projects. Moreover, if a MP could not

be completed, it was often difficult to find appro-priate alternatives for relatively large amounts offunds.

– Allocating human and organisational resources.Previous research has assessed the administrativecosts involved in CP implementation, includingthe calculation of staff workloads.10 This showsthat the beginning and end of each period are par-ticularly work-intensive due to the overlapping ofactivities related to the new and the old pro-grammes. The transition between programmingperiods can be associated with staff turnover ororganisational restructuring.11 In anumber of pro-grammes, authorities faced uncertainty in terms

9 Davies, S., and Gross, T., ‘The end of the formal programmingperiod 2000-2006’ [2007] IQ-Net Review Paper 19(1), EuropeanPolicies Research Centre, Glasgow.

10 SWECO, Regional governance in the context of globalisation –reviewing governance mechanisms & administrative costs. Admin-istrative workload and costs for Member State public authoritiesof the implementation of ERDF and Cohesion Fund (report for DGRegional Policy 2010).

11 Gross, T., and Davies, S., ‘Programmes in Transition - BetweenClosure and Start. Review of Programme Developments: Winter-Summer 2007’ [2007] IQ-Net Review Paper 20(1).

Table 1: Timetable for Closure 2007-13.

Date Action

31 December 2015 Deadline for final eligibility for expenditure. Article 56(1) General Regulation

30 June 2016 Deadline recommended for the submission of the last interim payment to EC

31 December 2016 Deadline recommended for the CA to submit to the AA application for payment of final balanceand final statement of expenditure

31 March 2017 Final date for the submission of closure documentsState aid - final date for the body granting the aid to pay the public contribution to the State aidbeneficiaries

31 March 2018 Global objective for the EC to close as many OPs as possible

31 March 2019 Deadline for the final reporting on non-functional projects

3 years after closure of pro-gramme

All supporting documents regarding expenditure and audits on the programme concerned arekept available for the EC and the ECAArticle 90 General Regulation

No time limit Report on pending recoveries and operations suspended due to legal or administrative proceed-ings

Source: Regulations and European Commission (2015) Op. cit.


of identifying and allocating the human resourcesor organisational roles for closure. These concernswere heightened by the broader shift of focus tothe new programmes.

Specific provisions introduced by the Commissionfor closure of programmes in 2007-13 responded tothese three sets of challenges.

Provisions to ensure timely and regular spendingincluded:– The scope for a programme to overspend 10% in

a particular Priority Axis without formally amend-ing the OP, provided this was compensated by anequivalent reduction in another Priority Axis ofthe same OP. This 10% flexibility option had al-ready been in place in 2000-06, but had originallybeen excluded for 2007-13.

– The potential for MAs to use ‘overbooking’ (i.e. thedevelopment of a project pipeline that is bigger involume than the financial scope of the pro-gramme) to promote the full absorption of funds.It should also be noted that retrospection (i.e. theaward of funds to an operation which has alreadyincurred significant expenditure or indeed is al-ready complete) was another option for pro-gramme authorities looking to absorb fundingquickly. However, this action was not encouragedby the Commission as it creates the risk of not re-specting eligibility requirements.

– In response to the global financial crisis, the Com-mission adapted its ‘decommitment’ rule thatfunds must be spent within two years of their al-location (n+2) to allow a third year in some Mem-ber States (n+3).

– Provisions related to audit included a shift to anannual audit process to identify and deal with ir-regularities throughout the programme period,not just at closure. The single audit procedure wasalso rolled out. Where so-called Article 73 status(General Regulation) had been granted to an OP,the Commission could draw assurance from AAwork rather than carrying out its own detailedchecks at closure.

There were specific provisions for certain types of op-erations.– Major projects could be split or ‘phased’ across two

programming periods.– Special provisions for FEIs included additional re-

porting requirements to be included in closurepackages but also the extension of spending dead-lines that meant that FEIs could continue to investin the real economy throughout 2016, i.e. beyondthe general deadline for eligible spending of 31 De-cember 2015.

– The guidelines also included provisions for othertypes of operation with specific challenges, no-tably revenue-generating projects.

Figure 2: Frameworkfor Analysing ClosureChallenges.Source: EPRC.


Regulatory provisions directly related to governanceand administration were limited:– A strengthened role of AAs had significant impli-

cations for closure, as a dedicated body in chargeof OP auditing activities was institutionalised (Ar-ticle 62 General Regulation).12

– The EC adopted a proactive approach to the clo-sure of the 2007-13 programming period, with anincreased focus on training and capacity-build-ing. Initiatives included: a dedicatedClosureUnit(Unit F.1) in DG REGIO to provide overall supportfor MS authorities on closure issues and internaltraining and guidance for staff. A series of 20 clo-sure seminars covering 28 MSs was organised byDG REGIO in the run-up to closure in 2013, re-sulting in a ‘questions and answers’ documentavailable online.13 DG REGIO also organised reg-ular technical meetings with AAs in MemberStates.

IV. Assessment of 2007-13 ClosureExperiences

1. Closure and Financial Absorption

Spending pressures have had an impact on the effi-ciency of the closure process. Programme authoritieshave taken measures to balance the demands of ef-fective absorption and efficient closure but, general-ly, a focus on the former has put pressure on the lat-ter. For the 2007-13 period, pressure on financial per-formance was increased by the late agreement on theEU's Multi-Annual Financial Framework and conse-quent delays in the negotiations of the NSRFs (Na-tional Strategic Reference Frameworks) and the OPs.Most programmes caught up in terms of financialabsorption.14 However, the spending profile of pro-grammes in different MSs varied considerably: someMS had absorbed the bulk of their funding relative-ly early in the period while others had much lowerlevels and had to accelerate spending in 2014 and2015 as closure approached.

A common response to absorption pressures asclosure approached was for MSs to set initial spend-ing deadlines that were earlier than the Commis-sion’s cut-off date at the end of 2015. These internaldeadlines were often accompanied by guidance fromnational authorities to programme bodies to facili-tate full absorption at the end of the programming

period.Overbookinganduseof theprovision for 10%flexibility in the allocation of funds to different OPpriorities was considered by programme authoritiesto be a valuable measure to ensure that the fundsavailable were absorbed by the spending deadline.This flexibility allowed programmes to respond tochanging circumstances (e.g. the impact of the glob-al financial crisis, differential intervention rates onlevels of demand frombeneficiaries, changes in avail-able funding due to exchange rate fluctuations, prob-lems with non-functioning projects etc.).

The option of phasing of operations was alsoutilised for major projects in some programmes toease absorption pressures. However, this option wasbureaucratically complex to implement as EC guide-lines set very strict procedures and discussion be-tween MS authorities and the EC on how a projectcould be separated in two phases was sometimeslengthy. Some MS applied retrospection in responseto implementation delays and absorption pressures,although there was awareness of the risks this bringsin terms of non-compliance with the relevant EU andnational rules and the consequences at closure of de-clarations of ineligible expenditure. Indeed, prob-lems were identified in some cases in the initialscreening of retrospective projects.15

The impact of the EC’s ‘single audit’ principle insimplifying the closure process was limited. In theo-ry, this initiative simplifies the burden of multipleaudits, which are a particular issue at the end of pro-gramming periods. However, this was not the case inpractice. The incentive for OPs to obtain single auditstatus has been limited: by the end of 2014, only 76of the 250 OPs had obtained this status (including 57

12 Davies, S., Gross, F. and Polverari, L., ‘The Financial Manage-ment, Control and Audit of EU Cohesion Policy: ContrastingViews on Challenges, Idiosyncrasies and the Way Ahead’ [2008]IQ-Net Thematic Paper 23(2), European Policies Research Centre,Glasgow.

13 European Commission, Q&A on the 2007-2013 programmesclosure (2013), view online at (last accessed 4 December 2017).

14 European Commission, Ex post evaluation of the ERDF andCohesion Fund 2007-13, Commission Staff Working Document,SWD(2016) 318 final, 19 September 2016, view online at (last accessed 4 De-cember 2017).

15 Government of Romania (2016) Response to Parliamentaryinterpellation 770 on the ‘State of EU funds absorption’, 4 April2016.


ERDF/CF OPs).16 Moreover, audit work has becomemore demanding, notably through the requirementthat AAs submit opinions based on a statistically rep-resentative (and thus larger) sample of checks.17

To optimise absorption, programme authoritiestook steps to target projects at risk of non-comple-tion. For example, in North Rhine-Westphalia, theMA established a working group responsible foridentifying projects at risk of not being completedand for finding ways of accelerating payments, in-cluding ensuring that payment claims are submitted.In Wales, there has been a structured approach toidentifying projects at different stages of completion(see Box 1).

2. Closure and Specific Types of Operation

The implementationof certain types of operationhashad implications for the quality of the closureprocess. This applies particularly to FEIs and MPs.EU provisions and MS actions have attempted to ad-dress the problems associated with dealing withthese interventions at closure but challenges remain,

largely related to uncertainties in regulations andguidance and in some cases limitations in capacityandexperience.MPswereoften subject to implemen-tation delays due to the challenging legal and techni-cal aspects of large investments. Programme author-ities have had to address the risk that these types ofprojects would not be finalised before the final peri-od of eligible spending at the end of 2015. Moreover,the regulatory framework for the 2007-13 period con-tained no deadline for the submission of MP appli-cations and, in practice, no final deadline for the ECto adopt the related decisions. As of 15 November2016, 19 MP applications from seven MSs were stillpending approval by DG REGIO with total associat-ed eligible cost of EUR 1 billion. Pending MP deci-sions complicated the closure of OPs as programmeauthorities did not know how to deal with the expen-diture in question when preparing the closure docu-ments. Pending decisions also created legal uncer-tainty for theMS. Inparticular,with the closure dead-line approaching, if the EC rejected a MP there wasan increased risk that the MS would not be able toreplace it with other eligible expenditure, whichwould lead to difficulties in fully using up the EUfunds by the time of closure.18 As noted above, phas-ing of MPs was an option for programme authoritiesbut this was accompanied by another set of chal-lenges. Finally, it is worth noting that in principle,some MPs approved before the end of 2012 were atrisk of non-compliance with State aid rules and con-cerns were raised by the European Court of Auditorsthat issues could emerge in the course of programmeclosure.19

Increased allocations for FEIs have been cited asa solution to absorption pressures and closure issuesby the EC in 2007-13. For instance, it urged the MA

16 European Court of Auditors, Taking stock of ‘single audit’ and theCommission's reliance on the work of national audit authorities incohesion (Special Report No 16, 2013).

17 Karakatsanis, G., and Weber, M., ‘The European Court of Auditorsand Cohesion policy’ in Piattoni, S., and Polverari, L. (eds), Hand-book on Cohesion Policy in the EU (Edward Elgar Press 2016),pp. 170-185.

18 European Court of Auditors, An assessment of the arrangementsfor closure of the 2007-2013 cohesion and rural developmentprogrammes (Special report N° 36/2016, 2017).

19 European Court of Auditors, More efforts needed to raise aware-ness of and enforce compliance with State aid rules in cohesionpolicy (Special Report No 24, 2016), p. 62.

Box 1: Closure of Projects at Risk of Non-completion in Wales.

The Welsh European Funding Office (WEFO), managing authority for ERDF and ESF programmes in Wales, organised a ‘clo-sure week’ in July 2015. This involved identifying a set of projects which were on the verge of closing, with all involved staffworking in a dedicated way only on closure of those projects for that week. This concentrated approach was found to be help-ful. Leading on from the closure week, three ‘closure meetings’ were held in July, August and September 2015. These identifiedapproximately 60 very overdue projects and invited all relevant internal staff to a special session. A whole day was blocked outfor each session with a ten minute slot allocated for each project. Relevant staff discussed problems related to closure (e.g. openissues, issues causing delay, actions to be taken). The aim was to come up with an Action Plan for each project with a realistictimescale and to identify any issues which needed to be addressed, such as lack of resources, difficulties obtaining informationfrom project sponsors and decisions required by the MA’s senior management team. This is assessed by WEFO to have workedvery well and it strengthened internal communication on closure.

Source: Interview with Welsh programme managers, March 2017.


of the Integrated OP in the Czech Republic to lookinto the possibility to use some of its remaining allo-cation for FEI activities.20 However, there are specif-ic technical requirements and challenges related tothese at the closure stage. As they give the possibili-ty of using the same funds several times through var-ious revolving cycles, closure applies to FEIs in a spe-cific way. In 2016, the EC noted that as closure ap-proached, there was an increased risk that amountscommitted to FEIs would not be fully absorbed at theend of the programming period and that continuedefforts would be needed to improve implementationin order to avoid losses at the end of the period.21

Programme authorities have experienced severalchallenges in incorporating FEI-specific require-ments in the OP closure process. Several took advan-tage of the later deadline for spending under FEIsbut this has had an impact on the closure procedureas programme authorities struggled to factor in suf-ficient time to allow the CA and AA to complete theirwork on time.22 Programme authorities have foundthat the closure of FEIs requires more administrativeeffort than for more straightforward operations, es-pecially where the experience of implementing andclosing FEIs is limited. In this context, EC guidancehas not always been helpful. The EC has produced arange of documents and guidelines for FEIs but therehas still been some uncertainty, for instance concern-ing cut-off dates for reporting reflows from initial in-vestments as part of the closure process. There havebeen specific pressures in the audit of FEIs at closure.The auditing of FEIs has proven to be complex, re-quiring specific competences, particularly in the fi-nal phase of programmes where assessments of theperformance of the instruments is carried out. TheECA noted the risk that this expenditure would notbe checked adequately for eligibility at the time ofclosure.23

3. Closure and AdministrativeCapacity/Governance

Finally, across MSs, the quality of the closure processhas been determined by the administrative capacityand governance approaches of programme authori-ties. A fundamental area of concern for closure re-lates to capacity issues. The problem is acute whereprogramme authorities were managing the closureof the 2007-13 OP(s) and the launch of the 2014-20

OP(s) simultaneously. For instance, the first full An-nual Implementation Report (AIR) for 2014-20 hadto be produced at the same time as the closure pack-age for 2007-13. In some cases, this overlap meantthat administrative focus turned to the launch of thenew OP(s) and the attention of programme authori-ties, beneficiaries and other stakeholders turned totheopportunities anddemandscoming fromthenewperiod, leaving little capacity to execute closureprocesses correctly and efficiently. In other contexts,particularly where closure was difficult or delayed,focus on closure impeded the launch of new OPs.These administrative pressures were exacerbated inspecific programme contexts: where MSs have notbeen involved in closing a programme before; wherea higher level of staff turnover among MAs meansthat institutional memory has been lost; where stafftime is limited by requirements to contribute to au-dits, evaluations etc.; and where management tasksare transferred between organisations.

MSshave takendifferent steps in response to thesepressures:– Recruitment. In some German Länder, additional

staff were recruited in advance of 2015 because theMA and Intermediate Body (IB) expected theworkload to increase. However, the workload wassignificantly higher even than had been anticipat-ed. Moreover, it is challenging to recruit tempo-rary staff who have the necessary experience andexpertise for closure. In Wales, the AA hiredagency workers as well as giving some existingstaff exclusive closure duties: one new agency per-son who spent 95% of their time on closure workplus two permanent team members. In France,some MAs introduced new fixed-ended contractsto deal with closure issues, compensating for stafftransferred to the MAs for the launch of 2014-20OPs.

20 European Commission, Task Force promotes better use of EUfunding (DG REGIO Newsroom item 31 March 2016), availableonline at (last accessed 4 December 2017).

21 DG Regional and Urban Policy, 2015 Annual Activity Report (27April 2016), p. 31.

22 Vironen, H., and Lehuraux, T., First signs of growth: progress withthe 2014-20 programmes [2016] IQ-Net Review Paper 38(1),European Policies Research Centre, Glasgow, p. 28.

23 European Court of Auditors, An assessment of the arrangementsfor closure of the 2007-2013 cohesion and rural developmentprogrammes (Special report N° 36/2016, 2017).


– Outsourcing. To alleviate the workload, some part-ners chose to externalise some closure tasks, suchas certification (e.g. some MAs in France).

– Switching the focus of work over time. For speci-fied periods, some programme authoritiesswitched the focus between closure of 2007-13 OPsand launch of 2014-20 OPs. In Greece, in 2015 forinstance emphasis was given and resources werecommitted to the launch of the 2014-20 OPs. In au-tumn 2016, the focus shifted to closure.

– Review of record keeping where there has been or-ganisational change or staff turnover. In some cas-es, such as Scotland and Wales there has been dis-cussion of the possibility of reorganising recordswithin government, to safeguard project sponsorsrecords when projects were wound up.

– Appointing closure managers or ‘champions’ in or-der to guarantee some focus on closure while staffare also engaged on the launch and implementa-tion of the new OP. In some cases, programme au-thorities identified networks of closure managersor ‘champions’ to become the main point of com-munication on closure, to be responsible for dis-seminating informationwithinMAs,CAsandAAsand to be the expert on the closure process with-in each unit. This approach was introduced to en-sure that consistent messages were being deliv-ered (e.g. Wales).

In terms of governance, effective programme closuredepended on the timely input of EU, national and

programme levels. The challenges of managing theprogrammeclosure process include the developmentof timetables and coordination arrangements acrossdifferent levels. Approaches varied, depending on ex-isting administrative arrangements, the size andscopeofprogrammes etc. Inmost cases, national gov-ernment bodies responsible for coordinating CPmanagement and implementation were involved,feeding into thedevelopment of EC closure guidance,developing domestic guidance and coordinating theclosure process across OPs.– In Germany, the first steps on closure were taken

at federal level, i.e. the Federal Ministry for theEconomyand Innovation (which is responsible forcoordinatingGermany-wide issues onCP, especial-ly the ERDF) asked the MAs of all programmes toprovide them with any questions they have on OPclosure, so that these can be discussed with the EC.National government bodies were also involvedalongside the EC in the organisation of a series ofworkshops across MSs on issues relating to OP clo-sure.

– In the United Kingdom, a UK-level Closure Packwasdevelopedbut therewas scope for programmeauthorities to develop tailored arrangements. Forinstance, a Wales-specific closure pack was pro-duced, specific to each Fund and programme.

– In France, closure guidance was developed by theHome Affairs Ministry (National CoordinatingAuthority for the 2007-13 period) in November2013 (see Box 2).

Box 2: National Closure Guidance in France.

National guidance refers to a non-binding ministerial guideline asking the MAs (directly under the authority of the Ministryfor that period) to:• Designate one person in charge of closure tasks within the Europe Unit (e.g. Haute-Normandie hired a person on a 6-monthcontract to manage the closure process)• Create a working group that ensures regular monitoring and programming of closure tasks• Establish a calendar for closure tasks• Follow specific advice regarding monitoring of certain projects (large projects, FIs, revenue-generating operations, ‘sleeping’operations) and other procedural good practices (e.g. regular reminders to beneficiaries)• Circulate ‘Operation Control Report’ as they are issued during the second semester of 2015 (as opposed to transfers all at once)• Closure indicator: Rate of paid and archived operations (e.g. specific monitoring instruments created in Picardie)• Scoreboards monitored by the National Coordinating authority:• Monitoring of ‘sleeping’ operations• Monitoring of payment of public co-funding• Monitoring of operations without ‘Operation Control Report’ and/or certificate for payment• Monitoring of under-implemented operations• General progress (not implemented, not paid

Source: Interview with French programme managers, March 2017.


At programme level, MAs often initiated coordina-tion arrangements that drew together other key bod-ies involved in closure: AAs, CAs and IBs.– A first step in this process often involved MAs in-

terpreting the EC closure guidelines and, if neces-sary, preparing additional written advice for theOP implementing bodies. Some MAs collected clo-sure questions internally and from CA and AA,and sent these to national authorities.

– To facilitate information dissemination, workinggroups were set up in several MSs, either at na-tional or programme level, or existing workinggroups were used to discuss closure issues at reg-ular meetings (e.g. United Kingdom, Germany,France, Romania). These working groups broughttogether the partners involved in closure, mainlyAA, CA, MA and IBs. In Romania, a formal Inter-Institutional Working Group led by the Ministryof European Funds supervised the closure of na-tional OPs. This working group was composed ofheads of MAs, IBs, CA and AA. In Wales, the MAre-established its own Closure Group (in 2008),alongside a United Kingdom Working Group, tokeep closure on the programme managementagenda. By mid-2016, the MA, CA and AA in Waleswere meeting monthly. This increased to fort-nightly from January 2017 and from March 2017moved to a short meeting every other day. How-ever, it should be noted that the establishment ofthese groups did not automatically guaranteesmooth coordination: there were still challengesin developing a common approach to different as-pects of the closure process, where MA and CA in-terpretations of EC guidance varied.

Governance arrangements were made in some casesto deal with specific closure tasks or objectives. Toavoid an excessive closure task at the end of the pe-riod, some programme authorities took a proactiveapproach toensuring regularityand legality in spend-ing. Programme authorities in Western Finland andFlanders (Belgium) aimed to close projects through-out the programming period (in effect ‘phasing’ clo-sure throughout the period). In Scotland and Wales,programme authorities embarked on a campaign ofquality assurance when closing individual projects,hoping that timely and complete closure at projectlevelwould translate to closure at theprogramme lev-el. Finally, it is worth noting that in a limited num-ber of cases, the closure process was viewed as an op-

portunity to disseminate the results and achieve-ments of programmes.24 For instance, Bavaria pro-duced a ‘closure brochure’ on the achievements of itsprogramme.

V. Conclusions

Overall, formal closure of ERDF and CF programmesin 2007-13 was carried out in an efficient manner.There was broad satisfaction among MSs with theguidelines providedby theECand the additional sup-port supplied. Generally,MSswere also satisfiedwiththeir own arrangements for the formal process of as-sembling and submitting closure packages. The re-search argues that beyond this formal process, clo-sure should be perceived as an integral part of pro-gramme implementation: influencing the allocationof remaining resources; in securing and raisingawareness of programmeachievements and legacies;and, in supporting an efficient transition to the nextprogramming period. In this respect, programme au-thorities face substantial challenges.

The aim to absorb the maximum available fund-ing before the spending deadline put pressure on theclosure process. For some MSs, programme closurein 2007-13 was more challenging than in 2000-06 dueto the impact of the economic crisis: lack of liquidi-ty has led to slower project implementation and thisin turn put pressure on closure as programme au-thorities struggled to absorb funds by the deadlinefor eligible spending. However, this pressure hasbeen eased by EC regulations (notably the 10% flex-ibility rule) and closure management strategiesamong MSs (including the use of ‘overbooking’). TheEC’s special measures to facilitate absorption forthose MSs experiencing the most severe impacts ofthe crisis (e.g. Greece) were valued in terms of effi-cient closure.

The implementation of FEIs and major projectshas had implications for the quality of the closureprocess. Programme authorities have experiencedseveral challenges in incorporating FEI-specific re-quirements in the OP closure process: the impact ofextended deadlines on FEI spending; the complexi-ty of FEI closure tasks, especially where knowledge,

24 Rodríguez Sáez, V., ‘Closure 2000-2006: state-of-play and lessonslearnt’ (INTERACT Newsletter, Autumn 2013).


experience and administrative capacity was limited;and specific pressures in the audit of FEIs at closure.In the opinion of some MS, the EC guidance on theseissues was not provided early enough. Programmeauthorities have faced difficulties in dealing with de-layed or withdrawn major projects as part of the clo-sure process. These interventions are associated withsignificant levels of funding and implementation of-ten involves complex legal and technical issues. Phas-ing has been pursued by MS as a means to alleviatepressures at closure and strengthen strategic impactby continuing the implementation of strategicprojects beyond closure. On the other hand, phasinginvolves several complex administrative proceduresthat complicate the closure process. For most pro-gramme authorities covered in the research, dealingwith non-functioning projects was not seen as an im-portant issue for the closure process.

Across MSs, the quality of the closure process hasdepended on the administrative capacity and gover-nance approaches of programme authorities. Gener-ally, programme authorities were managing the clo-sure of the 2007-13 programmes and the launch ofthe 2014-20 programmes simultaneously. In somecases, this overlap meant that administrative focusturned to launch of the new OPs. In other contexts,focus on closure impeded the launch of new OPs. Po-tentially, administrative resources can be stretchedsimultaneously across four programming periods:closing someresidual 2000-06OPs, closureof2007-13OPs, launch and implementation of 2014-20 OPs andinput into post-2020 thinking and debates. The cri-sis also had an impact on the administrative capaci-ty ofprogrammeauthorities aspublic administrationbudgets were cut and staff numbers fell. Closure de-mands strong coordination, not just across program-ming periods but between EU, national and pro-gramme levels and between MA, IB, CA and AA atprogramme level. More specific challenges are relat-ed to ensuring: optimal absorption of funds at clo-sure; regularity, legality in closure documentation;and, effective arrangements for compiling and dis-seminating closure packages. Akey challengewas en-suring sufficient capacity for AAs. The use of annu-al closure reports were generally viewed as positivein simplifying the closure process, providing assur-ance to the EC and easing the burden on MAs and

AAs at the end of programming periods. Neverthe-less, AA work is particularly intense at closure.

A range of measures have addressed these chal-lenges at MS level: advance planning for closure ear-ly in the programming period; proactive approachesto the identification and closure of potentially diffi-cult projects; outsourcing or recruitment of addition-al staff for closure tasks; and establishing dedicatedposts or structures as closure ‘champions’ to ensurethe issue is prominent across programme fora. Theprocesswas facilitatedby thepresenceofexperiencedstaff or external consultants that were involved inclosing programmes in 2000-06, as well as by variousinitiatives designed to monitor the timely implemen-tation of projects (e.g. setting early deadlines for com-pletion, identification and monitoring of projects atrisk of missing closure deadlines, monthly checks toensure that work is going according to plan, etc.). Thewell-timed establishment of dedicated workinggroups and preparation of targeted Action Plans forOPs closure, defining tasks, responsibilities anddead-lines, proved to be important for ensuring the time-liness and accuracy of the closure exercise.25

Looking forward, important lessons from closureprocess experiences can be highlighted for consider-ation in the post-2020 reform debate:– The strategic role of closure should be emphasised.

Astronger emphasis onprogrammeoutputs in theclosure process would strengthen this strategic as-pect, facilitate efforts to communicate CP achieve-ments ‘on the ground’ and help in defining thestrategic objectives of new programmes. Report-ing on the achievement of targets is a requiredpartof the closure package. However, the amount ofthe final payment is not directly linked to the ac-tual achievement of outputs and results. Althoughprogramme authorities were clear on the poten-tial financial consequences of errors or irregulari-ties in closure documentation, the relationship be-tween the reporting of achievements and the EC’sapproval of closure submissions was less clear.

– Closure should be included in broader post-2020simplification debates. Despite significantprogress, closure remains a complex and demand-ing process and incurs a substantial administra-tive burden for programme authorities, especiallythose in relatively small administrations (e.g. SI).Making the closure procedures less onerous anddecreasing the administrative burden are there-fore viewed as important (e.g. AT, SK).25 Michie, R., and Dozhdeva, V. (2017) Op. cit.


– The importance of timely and consistent input fromCommission services and capacity-building initia-tives. The timeliness and clarity of EU-level closureadvice and guidelines and a unified coordinationapproach across Commission services is seen asvital by programme authorities. Capacity-buildinginitiatives are also valued. For instance, the role ofAAs in OP implementation, including closure in-creased significantly in 2007-13 and is likely to doso again in 2014-20 and this warrants dedicated ca-pacity-building initiatives from the EU level.

– The value of close coordination between MA, AAand CA (e.g. in planning key stages and associat-ed deadlines in the closure process, in data gath-ering and database interconnectivity etc.).

– The need for more detailed discussion of closurereports at domestic level, with the involvement ofall relevant stakeholders, for instance through de-bates within monitoring committees.

– The need for adequate capacity and early planningof the allocation of administrative resources at MSand OP level. For instance, the relevance of design-ing and planning for the closure process at the be-ginning of the programme period, regular andtimely assessment of project completion and over-all timely finalisation of projects, regular report-ing and adding data to the closure registry on acontinuous basis, as well as provision of more de-tailed domestic guidance have been highlightedacross MS.

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