FAQ on checks of projects�

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�1.��What is first level control?

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In accordance with the Commission Regulation 438/2001, the Member States involved in the INTERREG IIIB CADSES Programme have established financial management and control procedures. Such procedures must verify the delivery of the co-financed products and services, the accuracy, the reality and the eligibility of the expenditure claimed, ensure compliance with the applicable national and Community and conformity with the Programme. Strict compliance with the following EC regulations must be ensured:

Council Regulation (EC) No 1260/1999 laying down general provisions on the Structural Funds � Commission Regulation (EC) No 1159/2000 on information and publicity measures to be carried out by the Member States concerning assistance from the Structural Funds

Commission Regulation (EC) No 448/2004 laying down detailed rules for the implementation of Council Regulation (EC) No1260/1999 as regards eligibility of expenditure of operations co-financed by the Structural Funds�

Commission Regulation (EC) No 438/2001, amended by Commission Regulation (EC) No 2355/2002, laying down detailed rules for the implementation of Council Regulation 1260/1999 as regards the management and control systems for assistance granted under the Structural Funds.

Such verifications (�first level control�) are performed by authorized certifying bodies. The Member States have chosen different procedures: some have opted for a centralised system, while others have created a decentralised system (find the updated list of certifying bodies in the relevant section).
The LP/PP will have to confirm that the institution designated for first level control is authorized to do so.
Any expenditure has to be certified by the institution in charge of first level control for this particular project. With this certification the institution certifies the correct use of ERDF funds. In case of doubts as regards the eligibility of expenditure, the institutions authorised for first level control, before certifying the expenditure, shall contact the respective Managing Authority for clarification.
The institutions delegated to perform the First Level control must be independent from the project�s activities and financial management (independent organisational unit), be qualified to carry out audits of accounting documents and also be familiar with ERDF rules, especially the rules concerning eligible expenditure. Austria and Germany have opted for a centralised certification system, whereas the other ERDF countries have a centralised certifying system
In case irregularities are detected, the procedures set up for 1st level control should make sure that the responsible PP is able to perform the necessary corrections. Should these corrections be not easily applicable, then the MA and the LP shall be informed immediately.
In the CADSES website the JTS is collecting the information on certifying bodies in the different countries. Please refer to this section or to your Cadses Contact Point.

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2.��What are the differences between a centralised and a decentralised certification system?

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In the centralised system the certification is carried out by auditors that act on behalf of the respective State. It guarantees unified and good quality standards, but in some cases the work load may turn into the delayed delivery of the final certification.
In the decentralised systems the auditors are appointed directly by the Project Partners, following specific conditions aimed at ensuring that the auditor chosen is able to perform the check as the European regulations require. In this case the delivery of the certification is faster but the Project Partner must verify carefully the working standard and the accuracy of the certifying body.
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3.� What is meant by "Confirmation by an independent auditor"?

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The certification of expenditure shall confirm the delivery of the products and services co-financed, the reality and eligibility of expenditure claimed and that national and community rules, especially Commission Regulation (EC) 448/2004, have been respected.
These certifications of expenditure are issued by a certifying body, i.e. a public or private accountant, independent from the project implementation. That means that this accountant is absolutely independent from the project activities as well as from the organisational unit where the project activities are carried out/ managed/ financed. The certifying body chosen must also be familiar with EU rules and regulations, and have sufficient experience in EU programme related auditing. In addition the CADSES Member States will ensure that the body issuing the certification of expenditure is authorised to do so and independent from the project implementation.
Last but not least, every auditor is authorized to perform checks only within the limits of the
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4.��What is the certification of expenditure ?�

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It is the certificate issued by the National certifying body after the 1st level control has been performed.
The certifying body checks the correct delivery of the products and services co-financed, the reality and eligibility of expenditure claimed and that national and community rules, especially Commission Regulation (EC) 448/2004, have been respected. The certifying body will then issue and countersign a so-called certification of expenditure, stating that the documents submitted are complete and have been checked for accuracy in contents and accounting terms:
1. the products and services to be delivered by the project partner have been delivered;
2. the expenditure claimed has been paid and is supported by receipted invoices or accounting documents of equivalent probative value;
3. the project complies with the subsidy contract and the applicable national and Community rules, in particular as regards public procurement, State aid, protection of the environment and equality of opportunity;
4. the amount of the eligible expenditure and of the national public co-funding that has been paid out;
5. the auditing authority/institution mentioned above is independent from the project implementation.
Each PP receives his own certification of expenditure and sends it to the Lead Partner; the LP will collect all the certifications and the total amount will be submitted for reimbursement to the Managing Authority (Payment request).

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5.��How many times a year can a payment request be submitted ?

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The subsidy contract states that there are four deadlines every year for the submission of the payment request: April 1st, July 1st, October 1st and December 1st. The projects are not obliged to follow each deadline compulsorily, and if for instance the July 1st deadline is skipped, then the corresponding costs can be gathered together with the costs incurred in the following months and be submitted in the payment Request of Oct. 1st.
It is nevertheless in the interest of the project to submit Payment request as frequently as possible, in order to ensure a regular cash flow.
The most important deadline is in any case the one of December 1st. The Project can use this deadline in order to sum up all the expenditures that may have not been claimed during the antecedent eleven months of the same year.
Projects must make sure that the payment requests submitted during some year stick to the budgeted yearly amounts. A delay in the request for reimbursement may have unpleasant effects as regards the n+2 rule.

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6.�� Do PP from non member states have to certify their expenditures ?

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In the 4th call. Encompassing the Neighbourhood approach, the �General Conditions applicable to European Community-financed grant contracts for external actions� at the point 15.6 are listed the cases where �an external audit of the Action�s accounts, produced by an approved auditor who is a member of an internationally recognised supervisory body for statutory auditing� shall be attached to the financing request submitted by a project partner. Please refer to the link
http://europa.eu.int/comm/europeaid/tender/gestion/cont_typ/st/index_en.htm
in the section J of the applicants� manual for the 4th call.