1. Which are the sources where the national co-financing can be covered from?
According to Guidelines for grant applicants, Section 2.3 – Indicative Allocation for this Call for Proposals: The national co-financing may take the following forms:
- Beneficiary’s own resources;
- Financial contributions by third parties, from sources other than the European Union. The rate of national co-financing shall be at least 8% of the total eligible costs of the Project, calculated per Lead/Project partner budgets in the project.
Each participating country shall decide on its own co-financing system (from national/ regional/local level or directly from the Beneficiary, or both from the national/regional/local level and from the Beneficiary itself). No resources from other EU Assistance may be taken into account as co-financing.
We recommend each applicant to contact the National Authority of their country related to this issue.
2. Please clarify if all projects should be based on the principle of non-profit and all incomes obtained will be deducted from the total value of the project?
According to Guidelines for grant applicants, Section 2.4.4 – Revenue: Grants shall not have the purpose or effect of producing a profit within the framework of the project. In case the project generates revenue, this may be used for covering project expenditure. If at the final balance there is a surplus of the revenue, this shall be reduced from the total eligible costs of the project. During project implementation, each beneficiary which generates revenue under the project, should keep detailed, timely, adequate and traceable information concerning the generated revenues.
3. Are the costs of rehabilitation, improvement and equipping of the respective building and adjacent land eligible?
Small scale investments are eligible up to maximum 500,000.00 EUR per project according to the Guidelines for grant applicants, Section 2.4.3 – Type of costs/expenditure. Information on eligibility criteria and an indicative list of eligible activities and costs that can be budgeted under the budget line 5: Infrastructure and works (small scale investments), are provided in the Guidelines. Also, please have in mind that: “Small scale investments have to be duly specified in the application to allow for a detailed presentation and evaluation of costs by describing at least the nature and quantity of each small-scale investment foreseen, the link with the relevant output as listed in the work plan and the related budget of the concerned partner. The costs for small scale investments, not explicitly mentioned in the Application will not be eligible.”
In accordance with Section 2.4.3 – Type of costs/expenditure, (5) Ineligible costs: purchases of land or buildings are not eligible.
Also, please take into account that the types of eligible and ineligible costs applicable for small scale investment projects are presented in detail in the Annex no.6 of the Guidelines.
4. Are costs for Project management consulting services eligible under this call for proposals, in case a Lead Beneficiary and/or beneficiaries do (does) not have the adequate professionals to perform some of the tasks related to the Project management?
Although employed staff or external experts, if the case, may perform the same type of tasks related to the project management and/or implementation, the costs for their involvement shall be budgeted from different budget lines, namely:
- Budget line Staff costs – for staff already employed or employed specifically for the project by the beneficiary under an employment document;
- Budget line External expertise and services – for external experts contracted for project management under a service contract (for more information regarding other type of costs included under this budget line, please see Budget Line 3 – External expertise and services)
With regard to the project management consulting services, according to Guidelines for grant applicants, Section 2.4.3 – Type of costs/expenditure: „Where the Lead Beneficiary and/or beneficiaries do(es) not have the adequate professionals to perform some of the tasks related to the Project, external experts may be contracted for these tasks. These costs shall be budgeted under the budget line “External expertise and services”.
Also, please have in mind, that the staff allocated by the lead partner and by the project partners for the management and coordination of project activities will be assessed during the Evaluation and selection process (see annex 09 – Quality Assessment Grid from the Guidelines, Operational assessment criteria).
5. Are consultancy services for the project preparation eligible, considering that they are provided before the grant contract endorsement?
According to Section 2.4.3 – Type of costs/expenditure, (2) Eligible direct costs have to meet several criteria including the following: a) they are incurred during the implementation of the Project, in particular: – costs relating to services and works shall relate to activities performed during the implementation period.
Notwithstanding the paragraph above, costs related to studies and documentation for projects including an infrastructure component, which are required during the evaluation stage (see section 2.4.3. Type of costs/expenditure –(6) Budget line specifications) are eligible even if they are incurred during the project preparation period which starts after the approval date of the Programme, respectively 18 December 2015.
6. Is the co-financing of the project mandatory for all types of applicants, including NGOs?
In order to ensure that the Lead Partner and Project Partners have adequate financial capacity to implement the project and are treated equally as regards of their financial inputs – all partners shall be requested to provide the same percentage of co-financing (at least 8%).
7. Regarding the staff costs, what rule and what type of contract will be used for the personnel involved in the implementation of the project (not contracted but employed)? Where they will be budgeted?
According to Section…. Of the Guidelines for Grant Applicants, staff costs, expenses, covering internal management or internal expertise, are eligible provided that they are paid for employees who are directly employed by the concerned beneficiary and who execute project related tasks. Staff can either be already employed or be employed afterwards, specifically for the project by the beneficiary. Expenditures on staff costs shall be limited to the following:
a) salary payments related to the activities which the entity would not carry out if the activities concerned were not undertaken, fixed in an employment/work contract, an appointment decision (both hereinafter referred to as “employment document”), or, by law;
b) any other costs directly linked to salary payments incurred and paid by the employer, such as employment taxes and social security payments, provided that they are: (i) fixed in an employment document or by law; (ii) in accordance with the legislation referred to in the employment document and with standard practices in the country and/or organization where the individual staff member is actually working; and (iii) not recoverable by the employer.
These expenditures will be budgeted under budget line 1 – Staff costs.
8. Is Project audit mandatory? Is this an eligible expenditure? On what budget line must be included?
In accordance with Guidelines for grant applicants, Section 2.4.3 – Type of costs/expenditure, Budget line 3 – External expertise and services, costs for expenditure verification are eligible under these conditions:
– For the Romanian Lead Beneficiaries/beneficiaries the costs for expenditure verification are not eligible from the budget of the Project, since the expenditure shall be examined free of cost by public officers of the Control Contact Point, established within the Ministry of Regional Development, Public Administration and European Funds, Romania;- For the Bulgarian Lead Beneficiaries/beneficiaries the costs for expenditure verification are eligible and shall be covered under this budget line. The expenditure verification costs are paid according to a contract between the project partner and controller which determines the exact remuneration payable by the partner to the controller for the control exercised for each specific project (BGN 2 400= EUR 1 227.12 per year/ 200.00 leva (102.26 euro) per month (including travel and accommodation costs and social insurance paid by the respective Bulgarian project partner). The procedure for nomination and designation of controllers for performance of expenditure verification of the Bulgarian beneficiaries in projects is executed by the Ministry of Regional Development and Public Works after each Bulgarian beneficiary submit to the DG TCM a “Request for Nomination of Controller” at the end (or 15 days after the end) of every reporting period.
For Lead Beneficiaries/beneficiaries from all other countries (Armenia, Greece, Georgia, Republic of Moldova, Ukraine and Turkey) it is compulsory to include in the budget certain amounts to be used for covering expenditure verification costs by external auditors.
9. Are costs for space / building acquisition and/or for renting a space / building eligible?
According to Annex 6 – Costs estimation small scale investments, Chapter 1, 1.1 – Land acquisition is an ineligible cost (N).
Related to renting costs, in Section 2.4.3 – Type of costs/expenditure, Budget line 6, only Office rent are eligible cost and shall be included in Office and administration costs.
Costs for renting a space and/or purchasing building (e.g. for an observation, visitor and information centre) or land are not eligible. (see Section 2.4.3 – Type of costs/expenditures, (5) Ineligible costs from the Guidelines).
10. Please indicate if costs with salaries paid for internal staff that is entitled (according to their job description) to elaborate studies and documentation for projects including an infrastructure component are also eligible even if they are incurred during the project preparation period ?
Staff costs related to elaboration of studies and documentation for projects including an infrastructure component can be included in the project budget even if they are incurred during the project preparation period.
The eligibility of these costs will be analysed in relation to the following aspects:
– they are in accordance with the provisions of art. 48.2 b-g of the EU Implementing Regulation 897/2014 and described in Section 2.4.3 – Type of costs/expenditure, (2) – Eligible direct costs, letters: b, c, d, e, f, g ( e.g they are justified with payrolls, there is a decision of the management of the institution to appoint the respective staff to elaborate the study/document, labour contract, job description, timesheet,etc);- all provisions of article 48.5 of the Implementing regulation no.897/2014 regarding cost of staff assigned to the Project are closely observed and demonstrated (ex. the cost of staff assigned to the project relate to the costs of activities which the Lead beneficiary/beneficiaries would not carry out if the project was not undertaken, level of salaries to be those normally borne by the organisation for the respective activity, cost relate to actual gross salaries)- they are in line with national legislation regarding the elaboration of studies and documentation related to infrastructure and works.
– the respective applicant (organisation) has competences related to the elaboration of feasibility studies/technical documentation for infrastructure works;
– the organisation specifies in the Application that the elaboration of feasibility studies/technical documentation was made with its own staff (after the date of 18 December 2015).
These costs will be included in Budget line 5 – Infrastructure and works, under Group of Activities – Investment, should be reflected in Annex 6 Cost estimation small scale investment and shall be included in the total amount of 500.000 Euro/project.