In case of late start of the project, compared to the starting date in the approved Application Form, is the end date of the project postponed? Can the LP change the payment forecast accordingly?

The projects are requested to catch up with their delays and are not allowed to postpone the end date of the project.

Is it possible to implement budget changes between budget lines prior to project starting without considering that as an in-project budget change?

No. After the approval of the Monitoring Committee changes are not allowed, until the signing of the Subsidy Contract. After the signature of the Subsidy Contract the rules indicated in the SEE Implementation Manual apply.

How could the SEE authorities support national controllers (in case of centralised control systems) in order to avoid extraordinary delays in verification of project partners? expenditure?

A working group of controllers has been set up (representatives of the controllers from each Member State) that meet regularly. An indicative deadline among the controllers has been agreed that from the end of the reporting period, they have to issue the declaration on validation of expenditure within 60 days. Improvement from the starting of the programme implementation has been made by each control system, no extraordinary delays have to be expected by the project partners. However, the cooperation of PP to present in due all necessary documents for the validation of expenditure is also necessary.

Some national controllers have stated that the verification of expenditure will take up to 3 months. If this deadline is respected, it will only be possible to include validated expenses for some PPs in the next reporting period. Will there be any consequences by this fact?

The SEE programme requests the electronic submission of the Application for Reimbursement and the declarations on validation of expenditure within 3 months from the end of each reporting period (and originals within 15 days from the electronic submission). In case declarations on validation of expenditure are not available within the deadline, the subsidy contract allows that the expenditure of the project partners not validated for the given reporting period within the deadline is included for the next reporting deadline to the reporting period concerned.

From the SEE Implementation Manual and control guidelines it follows that the costs incurred in one period have also to be paid in the same reporting period. This means that costs incurred in one period and paid in the following period are not eligible and will not be validated. Could you explicitly confirm this?

This is not correct. Each LP should try to report activities and related costs in the same reporting period. If this turns to be impossible, the LP shall report at least the activities, while costs ? as soon as paid and validated ? will be included in the following reporting period.

Is it possible that the relations between sponsoring and sponsored partners are defined in an Addendum to the Partnership Agreement? Is it possible that only the ERDF ?Sponsoring Partner? and the sponsored one signs the PA, or is it necessary that all PPs do so?

The Partnership Agreement is a compulsory annex to the Subsidy Contract and the main obligations among the partners and towards the LP are outlined there. However, if you find useful to have a more detailed Partnership Agreement or an addendum to clarify the rights and duties of your 10% PPs towards the LP more in detail, this can be done. If a special agreement is signed only between the ERDF ?Sponsoring? and the ?Sponsored? PP it shall be considered as an internal document (it shall not be submitted to the JTS, although the LP shall be fully informed), if it is an addendum to the partnership agreement and signed by all PPs of the project, the addendum has to be submitted to the JTS.

How the project can reimburse the travel costs of the speakers/experts participating in a project event, if only travel costs of the project staff are eligible?

Travel costs of external experts have to be always included in an external service contract. In case an external expert can not receive a fee for participating in a project event as speaker (e.g. public administration), a short contract should be signed by both parties stating that only travel costs and accommodation costs supported by invoices will be paid. These costs have to be reported under external expertise.

How to handle invoices for externalized services for the benefit of 10% Partners? Are they considered as PP own costs or how do they have to be distinguished in any way?

As explained in the SEE Programme Manual, in case of public procurement for services provided for the benefit of the 10% PP, the ERDF ?sponsoring partner? will carry out public procedures according to his national public procurement rules, will sign the contracts ? stating that they have been signed for delivering services for the benefit of the 10% PP ? and will be the addressee of the invoices. The service provider shall be paid directly by the ERDF partner as well. The costs incurred by the ERDF ?sponsoring partner? for the benefit of the 10% PP shall be distinguished from the regular costs of the Partner on the detailed list of invoices.

The 10% Partners follow the rules set for the ERDF ?Sponsoring Partner?. This means that for travel costs of any 10% Partner rules of the sponsoring partner is valid (per diem, etc.)?

Travel and accommodation costs for the 10% Partners are eligible only if these costs are supported by an invoice clearly addressed to the ERDF project partner (see Programme Manual p. 44). This means, that ?Per diem? contribution to 10% Partners are not eligible expenditure for the 10% Partners. Travel and accommodation costs for the 10% partners shall be also directly paid by the ERDF sponsoring partner, and reported under ?travel and accommodation? budget line.

If we want to pay travel costs for our 10% Partners for attending the kick-off meeting, can we pay them the invoice for gasoline, ?highway vignette? (or any other invoices for road tax)? If they have over night costs, can we pay also the invoice for hotel? This is according to our legislation and internal rules possible and legit.

Gasoline, vignette and road taxes of the 10% partner can not be paid by the ERDF ?Sponsoring partner? for the benefit of the 10% Partner. The main reasons behind this are the following: In any case of the use of own car or company car, a calculation sheet is also necessary for the verification of expenditure according to national or institutional rules (stating at least the distance, the unit rate and the total costs of the travel). This means, that the costs can not be paid only and directly on the basis of invoices (gasoline, highway vignette), and these costs can not be verified by the ERDF partner?s controller (calculated on the basis of national rules of the 10% partner), therefore these costs are not eligible expenditure.

Are NGOs eligible as project partners?

NGOs are eligible for ERDF funding, on the condition that they fulfill all the criteria foreseen for the bodies governed by private law. Detailed information on their eligibility for IPA funding are specified in the Programme Manual v.2.0, section 5.1.