A&E

H2020
Indicative
Audit
Programme
29 July 2019
Version 3.0
 HISTORY OF CHANGES

Version Publication date Changes

1.0 9 November 2017  Initial version

2.0 19 December 2018  Update of audit procedures (with reference v.2.0):

o A. Direct Personnel Costs N.: 7, 8, 12.
o B. Subcontracting N.: 13, 25, 26.
o D. Other Direct Costs N.: 5, 11, 26, 27.
 Addition of audit procedures (with reference v.2.0):
o ERC N.: 2, 3.
 Merge of audit procedures:
o B. Subcontracting N.13 (v.2.0) with N.14 (v.1.0).
o D. Other Direct Costs N.11 (v.2.0) with N.13 (v.1.0).
 Removal of audit procedures (with reference v.1.0):
o D. Other Direct Costs N.: 24, 25.

3.0 29 July 2019  Update of MSCA audit procedures.

TABLE OF CONTENTS

A. DIRECT PERSONNEL COSTS _________________________________________________ 1

General Procedures __________________________________________________________________ 1
Time Recording _____________________________________________________________________ 8
Specific Cases _____________________________________________________________________ 11
A.1 Employees (or equivalent) _________________________________________________________ 19
A.2 Natural persons with direct contract_________________________________________________ 30
A.3. Seconded personnel (against payment) ______________________________________________ 34
A.4 SMEs owners & _________________________________________________________________ 36
A.5 Natural persons not receiving a salary _______________________________________________ 36
A.6 Access to research infrastructure personnel costs ______________________________________ 38
Final General Control ________________________________________________________________ 39
B. SUBCONTRACTING________________________________________________________ 40
General Procedures _________________________________________________________________ 40
Contracting Authority________________________________________________________________ 50
Not Contracting Authority ____________________________________________________________ 51
Final General Control ________________________________________________________________ 53
D. OTHER DIRECT COSTS _____________________________________________________ 54
General Procedures _________________________________________________________________ 54
D.1. Travel costs and related subsistence allowances ______________________________________ 64
D.2. Depreciation costs of equipment, infrastructure and other assets _________________________ 67
D.3 Costs for other goods and services _________________________________________________ 73
D.5 Costs for internally invoiced goods and services _______________________________________ 78
Final General Control ________________________________________________________________ 80
E. INDIRECT COSTS _________________________________________________________ 81
F. SPECIFIC COST CATEGORIES ________________________________________________ 82
Costs for clinical studies _____________________________________________________________ 82
Costs for energy efficiency measures in buildings _________________________________________ 85
Access costs for providing trans-national access to research infrastructure ____________________ 87
Fusion programme__________________________________________________________________ 91
RECEIPTS _________________________________________________________________ 96
COORDINATOR ROLE ________________________________________________________ 98
SME – PHASE 2 __________________________________________________________ 100
ERC____________________________________________________________________ 102
ERA-NET COFUND ________________________________________________________ 104
MARIE SKŁODOWSKA-CURIE ACTIONS ________________________________________ 109
 A. DIRECT PERSONNEL COSTS
General Procedures
(*)
GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. Certified methodology 1 If the Beneficiary has a certified methodology for
6.2 claiming personnel costs:
a) Verify that the costs have been declared using
the certified methodology.
b) Verify that the Beneficiary did not conceal
information when presenting the methodology for
certification.
If the certified methodology has not been applied
or if the Beneficiary concealed information to the
EC / AGENCY / JU for its approval, report the
incompliances or the concealed information and
report the eligible costs based on actual costs
without proposing an adjustment.
Art. They must be actually incurred 2 Obtain from the beneficiary the detailed
6.1.( by the Beneficiary breakdown of personnel costs included in the
i) financial statements per reporting period, with
reference to the financial/ fiscal year used in the
computations. Reconcile the breakdown with the
claimed costs.

Art. 3 Select for testing a sample of persons based on the ERC

6.1.( following method:
i) 1) If the total personnel costs declared are below
the planning materiality level (5% of total costs
declared) select for testing only the person with the
highest amount declared.

2) If the total personnel costs declared are above

the planning materiality level (5% of total costs
declared) select for testing all the items with a
value higher or equal to 10% of the costs declared
for personnel costs and add randomly selected
persons until you reach either 50% coverage of the
personnel costs or a maximum number of 15
persons. A minimum of 5 persons must be selected
unless the population is less than 5.
Art. 4 a) Obtain the supporting documentation (payrolls,
6.1.( payslips, bank statements, contracts, time records
i) (timesheets), accounting records, usual accounting
practices, usual cost accounting practices, usual
remuneration practices, etc.) to be able to verify
the personnel costs.

b) Obtain from the Beneficiary details related to

the basic remuneration, mandatory complements,
variable complements, additional remuneration
included in the computations. The detail should
include type of personnel costs, name, duration of
the contract, position of the person, information
about method and productive hours used.

(*) When indicated in this column, the general procedure to be performed is not applicable and specific audit
procedures are required. See further sections SME-Phase 2, ERC, ERA-NET Cofund and Marie Skłodowska-Curie
Actions).
1
GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. 5 Depending on which type of personnel is included
6.1.( in the selected persons, perform the relevant
i) procedures from the sections A.1 to A.6, as well as
for "Time Recording" and "Specific cases
If systemic or recurrent errors are identified
request the Beneficiary to recalculate the declared
costs for the action by removing the effect of the
systemic or recurrent errors for the whole
population. Verify the accuracy and reliability of the
recalculation performed by the Beneficiary.
Art. Currency for financial 6 For beneficiaries with accounting established in
20.6 statements and conversion into other currency than the euro, verify that the
. euro amounts have been converted into euro using the
rate in accordance with Art.20.6.
Art. They must be incurred in the 7 a) Reconcile the hours declared for the action with
6.1 period set out in Article 3, with the provided time records (time-sheets or
(ii) the exception of costs relating declaration for exclusive work).
to the submission of the
periodic report for the last b) Verify that that the hours recorded in the time
reporting period and the final records do not include hours during the suspension
report (see Article 20); of the implementation of the action or outside the
duration of the action.
Double ceiling — Beneficiaries
must ensure that: c) If hours are declared outside the duration of the
- the total number of hours action verify that they relate to the submission of
worked declared in EU and the periodic report for the last reporting period and
Euratom grants for a person the final report.
for a year is NOT higher than
the number of annual d) Verify that the total number of hours declared in
productive hours used for the EU and Euratom grants for a person for a year is
calculation of the hourly rate; NOT higher than the number of annual productive
- the total amount of personnel hours used for the calculation of the hourly rate.
costs declared (for
reimbursement as actual costs) e) Verify that the total amount of personnel cost
in EU and Euratom grants for a declared in EU and Euratom grants for a person for
person for a year is NOT higher a year is not higher than the total personnel cost
than the total personnel costs recorded in the beneficiary's accounts for that
recorded in the beneficiary’s person for that year. (Not applicable for Unit Costs /
accounts (for that person for Average Personnel Costs).
that year).
f) Verify that all the persons selected for testing
have been paid by tracing to supporting documents
for a sample of months.
Art. They must be incurred in 8 Select for testing a sample of at least 1 person per ERC
6.1 connection with the action as Action from the persons selected for testing and
(iv) described in Annex 1 and review the CV, job profile, internet sources (e.g.:
necessary for its LinkedIn, etc.), scientific reporting and perform
implementation; interviews in order to verify that: 1) they have the
necessary qualifications for the performance of the
tasks attributed to them in the context of the
H2020 action and
2) verify their involvement in the action. (e.g.: Ask
them to describe their part in the project and the
work performed, etc.).

2
GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art They must be identifiable and 9 a) Verify if in accordance with the national
6.1 verifiable, in particular recorded accounting law the Beneficiary has the obligation
(v) in the beneficiary’s accounts in to have its annual statutory accounts certified by
accordance with the accounting an independent auditor.
standards applicable in the
country where the beneficiary - If yes: Request the statutory auditor's report for
is established and with the the years covering the duration of the audited
beneficiary’s usual cost period or if the latter is not yet available, for the
accounting practices; last 3 years for which a report is available. Verify
if the auditor's report is qualified for reasons
affecting the personnel costs. If the auditor's report
on the Beneficiary's statutory annual accounts is
not qualified for the personnel costs the costs are
deemed to have been recorded in accordance with
the accounting standards applicable in the country
where the Beneficiary is established.

- If no: Review the accounting records of the

beneficiary and verify that the personnel costs
declared in the financial statements were recorded
in accordance with the accounting standards
applicable in the country where the beneficiary is
established.

Art 10 Review the accounting records of the beneficiary

6.1 and verify that the personnel costs declared in the
(v) financial statements were recorded:
1) in the beneficiary's statutory accounting
accounts and derive from the payroll system;
2) in accordance with the beneficiary’s usual cost
accounting practices;
3) Reconcile the project cost accounting with the
General Ledger (GL) /analytical accounting books.
Art. 11 Review the accounting records of the beneficiary
6.1 and verify that:
(v) a) There are no corrections to the recorded
personnel costs (netting off, credit entry,
cancellation) which have not been taken into
consideration by the Beneficiary when preparing
the financial statements for the H2020 action.
Special attention should be paid to costs which
may be reimbursed under some circumstances by
the social security: maternity leave, long duration
illness etc. Periods of special leave, illness,
maternity leave, etc. in the time recording or
involvement in other projects if not working fully
for the action increase the risk that there are
amounts received from other sources to cover part
of the salary.
b) The personnel costs have not been reinvoiced by
the beneficiary to another legal entity.
c) In addition to accounting records review the
contracts or equivalent and verify that the persons
have not been funded by other sources (other
grants and contracts funded by the EU budget,
national funding, etc.).

3
GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. 12 Obtain information from the Beneficiary whether
6.5 the audited entity participates in other EU
(b) programmes, in particular Structural Funds, Social
Fund, etc. and obtain a list of the other EU
actions/projects running during the audited period.

Only if the Beneficiary does not have a developed

IT accounting system including project accounting
that prevent double charging of costs and incomes
to different projects, then obtain for 5 other
actions/projects the list of persons declared under
personnel costs. Verify that none of persons
selected for testing are included in the cost claims
of the 5 other projects/actions.

Art. They must comply with the 13 a) Verify if in accordance with the national
6.1 applicable national law on accounting law the Beneficiary has the obligation
(vi) taxes, labour and social to have its annual statutory accounts certified by
security an independent auditor.

- If yes: Request the statutory auditor's report for

the years covering the duration of the audited
period or if the latter is not yet available - for the
last 3 years for which a report is available. Verify
if the auditor's report is qualified for reasons
affecting the personnel costs. If the auditor's report
on the Beneficiary's statutory annual accounts is
not qualified for the personnel costs the costs are
deemed to comply with the applicable national law
on taxes, labour and social security.

- If no: Review collective labour agreement,

employment contracts (or equivalent appointing
acts), payslips and verify if they comply with
applicable national law on taxes, labour and social
security, government acts or directives.

Art. 14 Verify that the Beneficiary’s name appears as the

6.1 ‘employer’ in the employment contract or the
(vi) equivalent appointing act. For seconded employees
the 'employer' will be the entity which provided the
seconded staff.
Art. They must not include any 15 Review the personnel cost components included in
6.2 indirect costs the hourly rate and verify that no indirect costs are
included. The beneficiary may not use estimations
or key driver to apportion costs of indirect nature,
as direct costs to the project. Only costs directly
attributable to the action should be declared.

4
GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art Article 6.1.(a), (iv), (vii); Art.35.1; 16 Confirm that the Beneficiary signed a
6.1. Art. 6.5 (b); Art. 6.5 (a)(x). representation letter stating that the costs charged
to the action are:
a) incurred in connection with the action as
described in Annex 1;
b) necessary for the implementation of the action;
c) reasonable and justified;
d) comply with the principle of sound financial
management, in particular regarding economy and
efficiency;
e) costs are incurred in absence of conflict of
interest;
f) did not contain any costs declared under another
EU or EURATOM grant
g) costs incurred during suspension of the
implementation of the action.
Art. c) reasonable and justified 17 Crosscheck the information included in the
6.1. documents related to the implementation of the
action (Annex I, minutes of project meetings,
management reports, scientific reports) and
inquiries of management with the extent and
timing of the hours declared for the action in order
to verify their reasonability.
Art. Costs incurred by linked 18 Verify that the costs incurred by linked third parties
6.3 third parties are eligible if fulfil - mutatis mutandis - the general specific
they fulfil - mutatis mutandis - conditions for eligibility set out in Art. 6.1 and Art.
the general specific conditions 6.2
for eligibility set out in Art. 6.1
and Art. 6.2 and Art. 14.1.1 (on
linked third parties)
Art. 19 a) Verify that the third parties, for whom costs
6.3 were incurred and claimed, are included in the GA
including amendments.

b) Verify that their participation in the action has

not been terminated.
Art. In-kind contributions 20 a) Verify that the seconded staff free of charge
6.4 provided free of charge are fulfil — mutatis mutandis — the general conditions
eligible direct costs (for the and specific conditions for costs to be eligible (see
beneficiary [or linked third Article 6.1 and 6.2)
party]), if the costs incurred by
the third party fulfil — mutatis
mutandis — the general and
specific conditions for eligibility
set out in this Article (Article
6.1 and 6.2) and Article 12.1.

5
GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. 21 a) Verify that the seconded staff free of charge
6.4 fulfils the additional eligibility conditions set out in
Article 12.1.:
a) Verify that the Third Parties and their
contributions were foreseen in Annex 1 or approved
by the EC / AGENCY / JU.

b) Verify that the beneficiaries limited the costs

declared for in-kind contributions free of charge up
to the costs incurred by the third parties for the
seconded persons, corresponding to the time the
person has worked for the action. Obtain the
supporting documents that demonstrate the actual
cost borne by the Third Party (e.g.: payslips,
accounting entries, etc.). Please note that if the
seconded person is working in the premises of the
third party the direct costs actually incurred by the
third party may be increased by a flat rate of 25%
on these costs. Refer also to section Specific cases
- Costs related to public officials.
Art. Ineligible costs (other than 22 Identify items related to return on capital (e.g. ERA-
6.5.( those not meeting the dividends, equity shares, etc.) included in the costs NET
a).(i) general and specific claimed. However, complements based on overall Cof.
criteria): financial performance of the organisation (e.g.
- costs related to return on profitability or surplus) may be accepted as
capital variable complements, if they fulfil the conditions
of eligibility in Art.6.1 and Art. 6.2.
Art. - debt and debt service 23 Identify items related to debt and debt service
6.5.( charges charges (e.g. loans on principal and/or interest, over
a).(ii a period of time) included in the costs claimed.
)
Art. - provision for future losses 24 Identify provisions for future losses or debts
6.5.( or debts included in the claimed remuneration components,
a).(ii for example redundancy payments.
i)
Art. - interest owed 25 Identify items related to interest payments on
6.5.( borrowed capital in the costs claimed.
a).(i
v)
Art. - excessive expenditure 26 Compare the hourly rate of each person included in
6.5.( the sample with the average hourly rates of
a).(v personnel performing similar tasks and
) responsibilities or with the applicable SME owner
unit cost rate. Consider if the costs declared are
excessive by applying professional judgement.
Calculate the resulting hourly rate for comparison
purposes in case the employee signs a 'declaration
on exclusive work for the action'.

6
GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. - reckless expenditure 27 Compare the hourly rate of each person included in
6.5.( the sample with the average hourly rates of
a).(v personnel performing similar tasks and
) responsibilities or with the applicable SME owner
unit cost rate. Consider if the costs declared are
reckless by applying professional judgement.
Calculate the resulting hourly rate for comparison
purposes in case the employee signs a 'declaration
on exclusive work for the action'.
Art. - currency exchange losses 28 Identify any currency exchange losses included in
6.5.( the costs claimed.
a).(v
i)
Art. - bank costs 29 Identify any bank costs included in the costs
6.5.( claimed.
a).(v
ii)
Art. - deductible VAT 30 Identify any deductible VAT included in the costs
6.5.( claimed.
a).(v
iii)
Art. - costs incurred during 31 Identify any claimed costs during the project
6.5.( suspension of the suspension periods.
a),(x implementation of the action
) (according to Art. 49)
Art. - costs declared under 32 In the Beneficiary receives an operating grant
6.5.( another EU or Euratom grant, in financed by the EU or Euratom budget in the same
b) particular indirect costs if the period as the action, verify that no indirect costs
beneficiary is already receiving are claimed on the personnel costs for the financial
an operating grant financed by years covered by the operating grant.
the EU or Euratom budget in
the same period.
Art. The Beneficiaries must keep 33 If the Beneficiary has presented digital or
18.1 the original documents. Digital digitalised accounting documents confirm that they
. and digitalised documents are are authorised by the applicable national law.
considered originals if they are
authorised by the applicable
national law.

7
Time Recording
GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. For persons who do NOT work 34 a) Obtain the time records of the Beneficiary
18.1 exclusively for the action, the for the persons working for the H2020
beneficiaries must: show the actual action. Obtain an understanding of the time
hours worked, with reliable time records recording procedures of the Beneficiary.
(i.e. time-sheets) either on paper or in a Review internal guidelines, review the
computer-based time recording system. system and perform interviews.
Time records must be dated and signed
at least monthly by the person working b) If the time-recording system is
for the action and his/her supervisor. If computer-based verify that:
the time-recording system is computer- 1) electronic signatures linking the electronic
based, the signatures may be electronic identity data with the electronic validation
(i.e. linking the electronic identity data data require a password and a user name;
(e.g. a password and user name) to the 2) there is a documented and secure
electronic validation data, with a process for managing user rights and
documented and secure process for 3) an auditable log of all electronic
managing user rights and an auditable transactions.
log of all electronic transactions).
ONLY costs for personnel assigned to In case of contradicting evidence which
the action (i.e. working for the action shows that the personnel might not be
according to internal written assigned exclusively to the action, follow
instructions, organisation chart or other procedure 37.
documented management decision) can
be eligible. Reliable time records will
normally be sufficient proof of the
assignment to the action — unless there
is other contradicting evidence (e.g. the
employment contract indicates that the
person was hired to work on another
project)

Art. Time records should include, as 35 a) Verify that the provided time records,
18 minimum: including electronic time records, include the
- the title and number of the action, as minimum requirements:
specified in the GA; 1) the title and number of the action, as
- the beneficiary’s full name, as specified in the GA;
specified in the GA; 2) the beneficiary’s full name, as specified
- the full name, date and signature of in the GA;
the person working for the action; 3) the full name, date and signature of the
- the number of hours worked for the person working for the action;
action in the period covered by the time 4) the number of hours worked for the
record; action in the period covered by the time
- the supervisor’s full name and record, with at least month level granularity;
signature; 5) the supervisor’s full name and signature;
- a reference to the action tasks or work 6) a reference to the action tasks or work
package described in Annex 1, to which package described in Annex 1;
the person has contributed by the
reported working hours.
Information included in timesheets b) Verify that the information included in
must match records of annual leave, the time records match records of the taken
sick leave, other leaves and work- annual holidays, statutory holiday, sick
related travel. leave, other leaves, and work-related travel.

8
GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. For persons who work exclusively 36 For persons who work exclusively for the
18 for the action (regardless if they are action, if they submit a declaration:
full-time or part-time employees), the
beneficiary may: a) Verify that is signed by the person who
− sign a ‘declaration on exclusive work worked exclusively for the action. Only one
for the action’ (one per reporting declaration per reporting period can be
period), to confirm that the person accepted.
worked exclusively for the action, either:
− during the whole reporting period or b) Verify that the declaration is dated and
− during a an uninterrupted time-period, countersigned for acceptance by the person
covering at least a full natural month concerned.
within the reporting period.
The declaration must be dated and c) Verify that the period covered by the
countersigned for acceptance by the declaration represents an uninterrupted
person concerned and his/her time-period of at least a full calendar
supervisor. month within the reporting period.
Intermittent (i.e. sporadic or random) periods
‘Exclusive work’ means that the person of ‘exclusive’ dedication can NOT be subject
carried out NO OTHER activities for the of a declaration. If a person worked
beneficiary than those of the action. randomly for the action after an
uninterrupted time-period covered by a
declaration, time records for the period of
random work should be available.
If a person worked under different regimes
during the reporting period (exclusive and
non-exclusive), the declaration may be used
ONLY for a period of exclusive work. The
other months must be recorded with time-
sheets.
If there were several periods of exclusive
work during one reporting period, the
beneficiary may choose to use the
declaration for the longest one (and use
monthly time-sheets for the others).

d) Review the CV and information found in

the internet including the beneficiary
website to identify if there are any
contradictions with the declaration of
exclusive work for the action.

e) Cross check the declaration with the

information included in the scientific reports.

9
GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. If time records are not reliable, the 37 Request the Beneficiary to provide
18 Commission / Agency may exceptionally alternative evidence for the persons for
accept ‘alternative evidence’ if it proves whom there is no time records (or self-
the number of hours worked on the declaration) or there is contradicting
action with a similar (or at least information on timesheets.
satisfactory) level of assurance
(assessed against generally-accepted Draw the attention of the Beneficiary that
audit standards). Examples of possible the alternative evidence provided will be
alternative evidence (non-exhaustive verified against the 3 criteria:
list): travel documents proving 1. Clear identification of the person
participation in a project meeting concerned
(boarding pass, obliterated travel ticket, 2. Clear link to the project under scrutiny
hotel invoice, etc.); agenda and minutes 3. Possibility to quantify time spent on
of the meeting; attendance lists; project-related tasks. Alternative evidence
working papers; computer and will only be accepted if these three criteria
laboratory log books; are met.
professional/personal diaries;
documents related to presentations; Highlight the necessity that for each piece
scientific publications; correspondence of alternative evidence the time spent on
such as letters, notes, memos, emails; the project should be quantified.
etc. The auditors will use the following
three criteria to assess how credible the Review the alternative evidence received
alternative evidence is: and verify for each piece of alternative
1. Clear identification of the person evidence if all the 3 criteria are fulfilled.
concerned
2. Clear link to the project under Verify that there is no contradiction between
scrutiny the pieces of evidence provided or overall.
3. Possibility to quantify time spent on
project-related tasks. Alternative
evidence will only be accepted if these
three criteria are met.

10
Specific Cases
GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. Personnel costs for ERA chairs — 38 In case the Beneficiary claims personnel
6.1 Are eligible even if the salary is above costs for ERA Chairs, determine whether
national salaries, provided that it does the level of remuneration is indicated in
not go beyond normal EU/international Annex 1.
salaries for similar positions (since the
ERA chairs aim to incentivise If it is, identify possible differences
international mobility for internationally between the salary claimed with the one
outstanding researchers and research indicated in Annex.
managers. When the level of
remuneration of the ERA Chair is If it is not, ask the Beneficiary to
indicated in Annex 1, this will be duly demonstrate that the salary does not go
taken into account in case of check, beyond that of EU/international salaries
audits or reviews for similar positions.

Check the evidence provided in order to

support the salaries for similar position
for the same seniority and level of
technical/scientific skills required for the
relevant job category.
Art.6. Teleworking - Remuneration costs of 39 a) Determine if authorizing teleworking
2.A.1 employees (or equivalent) not working (not working on the premises) is the usual
on the premises of the beneficiary (i.e. practice of the Beneficiary. Review the
teleworking) may be accepted as internal guidelines and procedures of the
eligible if it is the beneficiary’s usual Beneficiary for personnel and observe if
practice (i.e. if clear rules are available). not working on the premises is regulated
The system in place must make it in these documents. Certain research
possible to both identify and record the work requires employees to work off the
hours worked for the action. premises of the employer at a research
site. This is not considered teleworking
but a usual work activity. Take this into
account and corroborate information
from time records, reports/results from
work done, research logs etc.

b) Assess if the internal guidelines and

procedures of the Beneficiary for
personnel have been set up based on
objective criteria regardless of the source
of funding.

c) Review the time recording system in

place and verify if it allows both
identifying and recording the hours
worked for the action for persons
teleworking (not working on the premises)
of the Beneficiary.

11
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art.6. Benefits in kind - Costs of benefits in- 40 a) Review the components of the
2.A.1 kind provided by the beneficiary to its remuneration and identify benefits in-
personnel (e.g. costs of a company car kind (company car, lunch vouchers, other
made available to certain categories of coupons with purchasing power,
employees for their own use) or of subscriptions for sport centres, etc.).
quasi-financial benefits (e.g. costs of
lunch vouchers) may be accepted as b) Verify if they are registered in the
eligible if they are justified and Beneficiary's accounts.
registered as personnel costs in
conformity with the beneficiary’s usual c) Verify if they are justified in
remuneration practices. Like all costs, accordance with the usual Beneficiary's
they must fulfil the eligibility conditions remuneration practices.
set out in Article 6.
d) Assess if the usual remuneration
practices of the Beneficiary for personnel
have been set up based on objective
criteria regardless of the source of
funding.

e) Verify that the eligibility conditions of

Article 6 are being fulfilled.

Art.6. Recruitment costs - Recruitment costs 41 Identify any claimed costs related to the ERC
2.A.1 are generally not eligible as direct recruitment procedures (job analysis,
personnel costs, because the beneficiary announcement, evaluation, selection, etc.).
is required to have the necessary
human resources to implement the
action. If a beneficiary needs to recruit
additional personnel during the action
duration, the related costs would be
considered part of the entity’s normal
indirect costs, which under Horizon
2020 are covered by a 25% flat-rate of
the eligible direct costs.

12
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art.6. Costs for students, PhDs and other 42 a) Review the claimed personnel costs
2.A.1 researchers under scholarship, and identify any included costs for
internship or similar agreements students, including PhD (scholarship,
(not employees) — Costs of students internship or other similar agreement (not
that work for the beneficiary can be employees)).
accepted, if the agreement is work-
oriented (not training-oriented: i.e. not b) Verify that the eligibility conditions of
aimed at helping the student to acquire Article 6 are being fulfilled.
professional skills).
PhD agreements will be considered c) Verify that their remuneration
work-oriented. However, time for (fellowships/scholarship/stipends)
training, if any, may NOT be charged to complies with the applicable national law
the H2020 action. on taxes, labour and social security. Verify
there is a legal basis for students'
Fellowships/scholarships/stipends remuneration for work.
— Can be charged to the action (as
personnel costs), if they fulfil the d) Verify that the assignment of the tasks
conditions set out Article 6.1 and to the students respects the laws in force
6.2.A.2, and in particular: in the place of establishment of the
- the remuneration complies with beneficiary. (e.g.: the maximum time they
the application national law on taxes, are allowed to work having in mind their
labour and social security teaching/studying activities)
- the assignment of tasks
respects the laws in force in the country e) Verify that they have the necessary
of the beneficiary qualifications for the performance of the
- the students have the tasks attributed to them in the context of
necessary qualifications to carry out the the H2020 action and verify their
tasks allocated to them under the involvement in the action. If the
H2020 action. agreement is training-oriented (i.e. aimed
at helping the student to acquire
professional skills) its cost can NOT be
charged to the grant.
Art. Cost for exemptions from 43 a) Review the claimed personnel costs
6.2.A. academic fees — The fees (or part of and identify if the Beneficiary included
1 them) are eligible as personnel cost, if any exempted academic fees for
the student’s contract includes the students.
amount of waived fees as part of
his/her remuneration. The other b) Verify that the student’s contract
conditions set out in Article 6 have to be includes the amount of waived fees as
fulfilled as well (e.g. the full part of his/her remuneration.
remuneration, included the value of the
waived fees, must be recorded in the c) Verify that the value of the included
university’s accounts). waived fees is recorded in the university’s
accounts.

d) Verify that the eligibility conditions of

Article 6 are being fulfilled.

13
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art.6. Parental leave - Salaries and social 44 a) Review the claimed personnel costs
2.A.1 security contributions paid during and identify any costs related to parental
parental leave (either maternity leave or leave Inquire if there was any parental
parental leave) are eligible as part of leave taken in the periods in the audit
the basic salary only if: scope.
− they are mandatory under national
law, under the relevant collective labour b) Verify if parental leave payments are
agreement (e.g. statutory maternity mandatory under national law, under the
pay) or under the employment contract relevant collective labour agreement (e.g.
− the beneficiary has actually incurred statutory maternity pay) or under the
them employment contract.
AND
− they are not reimbursed by national c) Verify that the beneficiary has actually
(central, regional or local) authorities incurred the costs for parental leave.
(i.e. only the net amounts paid by the Review accounting records, payroll, bank
beneficiary are eligible) statements and payslips.

d) Verify that parental leave is not

reimbursed by national (central, regional
or local) authorities.

Please note: Time spent on parental

leave may not be deducted when
calculating the hourly rate per month.
However, beneficiaries may declare
personnel costs incurred in periods of
parental leave in proportion to the time
the person worked on the action in that
financial year.
Art.6. Costs related to public officials - 45 a) Review the claimed personnel costs
2.A.1 For public bodies, the costs related to and identify any costs related to public
public officials paid directly from officials.
central, regional or local government
budgets may be considered eligible, if b) Verify for these costs that the eligibility
they fulfil the conditions set out in conditions of Article 6 applied to the
Article 6 (applied to the central, regional central, regional or local government
or local government employing the employing the public officials are being
public officials). In this case, the public fulfilled.
officials will be considered as in-kind
contributions (resources made c) Verify for these costs that they fulfil
available) provided by a third party (the the eligibility conditions of Article 12 as
government) free of charge (see Article in-kind contributions (resources made
12). available) provided by a third party (the
government) free of charge.

14
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art.6. Supplementary contracts – 46 a) Review the claimed personnel costs
2.A.1 Supplementary contracts for and identify any remuneration based on
participation in projects (whatever their supplementary contracts.
form) are acceptable if it is the
beneficiary’s usual practice and b) Review internal procedures of the
compatible with national law. Beneficiary and perform interviews in
The remuneration will be qualified as order to determine if it is the usual
basic or additional remuneration, practice of the Beneficiary to use
depending on the scope (national OR Supplementary contracts.
EU/international) and amount (above,
equal or below usual remuneration c) Assess if the usual remuneration
practices for national projects). practices of the Beneficiary have been set
up based on objective criteria regardless
of the source of funding.

d) Verify that supplementary contracts

are compatible with national law of the
Beneficiary.

Art.6. People working exclusively on the 47

2.A.1 action- Verify that the Beneficiary calculates the
There is NO different calculation personnel costs of persons working
method for staff working 100 % on the exclusively on the action applying the
action. Since there is no obligation to same methodology as for the rest of the
keep time-sheets for periods covered by employees of the same category/type
a declaration on exclusive work, across all H2020 participations. In
beneficiaries should report: particular:
- for annual hourly rates: a pro-rata of - for annual hourly rates: a pro-rata of
the annual productive hours the annual productive hours
corresponding to the period covered by corresponding to the period covered by
the declaration (at the annual hourly the declaration (at the annual hourly rate)
rate) - for monthly hourly rates: 1/12 of the
- for monthly hourly rates: 1/12 of the annual productive hours (either option 1
annual productive hours for each month or 3) for each month actually worked for
actually worked for the action in the the action in the period covered by the
period covered by the declaration (at declaration (at the monthly hourly rate).
the monthly hourly rate).
Verify if any month has to be removed
If the declaration covers months in from the calculation due to absences
which the person was absent for more covering more than half of the working
than half of the working days those days of the month.
months can NOT be taken into account
to calculate the hours worked in the
action (— unless the absence is linked
to annual leave AND the duration does
not exceed the pro-rata of annual leave
entitlements corresponding to the
period covered by the declaration).

15
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. Employees hired during on-going 48 Refer to the calculation example from
6.2.A. financial year - (at the end of the AMGA Article 6.2.A.1 (1.1.4).
1 reporting period) — Since these Determine the pro-rata of the annual
employees did not work for the productive hours correctly and calculate
beneficiary during the last financial the eligible costs for employees for who
year, the hourly rate can only be there is no closed financial/ fiscal year
calculated on the basis of the personnel based on the actual costs incurred during
costs incurred during the ongoing the ongoing financial/ fiscal year.
financial year.

Art. End-of-contract indemnities - Since 49 a) Review the personnel costs claimed

6.2.A. the entitlement to end-of-contract and identify if any end-of-contract
1 indemnities is most often generated indemnities have been included in the
over a period of time longer than a personnel costs. If so verify that it was
financial year, the beneficiary may not included in the calculation of the
charge the corresponding part of the hourly rate but calculated separately.
indemnity in the reporting period in Review employment legislation, payroll
which the employee’s contract ends. records and general ledger, etc..
— but outside the hourly rate (i.e.
separately and on top of the personnel b) Verify that the end-of contract
costs declared on the basis of the indemnities arise from the applicable
hourly rate) AND only for the part that national labour law.
corresponds to the time worked by the
person on the action (i.e. pro-rata of the c) Verify that the end-of contract
total time during which the entitlement indemnities are recorded in the accounts
was generated). of the beneficiary.
Moreover, the indemnity can be
accepted ONLY if it: d) Verify that the end-of contract
- arises from the applicable national indemnities are incurred during the action
labour law and duration (although the actual payment
- is recorded in the accounts of the may take place latter).
beneficiary and
- is incurred during the action duration e) Verify that only the part of the end-of-
(although the actual payment may take contract indemnity that corresponds to
place latter). the time worked by the person on the
action was charged (i.e. pro-rata of the
total time during which the entitlement
was generated).

16
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. Employment contract remunerated 50 a) Review employment contracts and the
6.2.A. "per hour" - Some employment personnel costs claimed and identify if
1 contracts do not establish a fixed salary there is any employee who has an
and a number of hours to be worked, employment contract remunerated per
but an amount to be paid for each hour hour, and for which individual productive
worked by the employee. In those cases, hours (option 2) are used.
individual annual productive hours (i.e.
option 2) can only be applied if all of b) Verify that the 4 conditions mentioned
the following conditions are fulfilled: in the condition to be checked are
a) the employment contract explicitly fulfilled.
fixes the hourly rate to be paid b) the
employment contract established that
the salary is the result of multiplying
the hourly rate by the number of hours
worked c) the total salary paid under
the employment contract is identifiable
and supported by auditable documents
(e.g. payslips and declarations to the tax
authorities) d) the employment contract
is the only contract between the person
and the entity (i.e. there is no other
parallel contract). If those conditions are
fulfilled, the ‘individual annual
productive hours’ may be calculated as
follows: {total salary paid to the
employee in the financial year divided
by hourly rate fixed in the employment
contract}.
Art. Personnel costs on the basis of the 51 a) Obtain an understanding of the usual
6.2.A. usual accounting practices - For cost accounting practice by reviewing the
1 personnel costs declared on the basis of necessary supporting documentation
the beneficiary’s usual cost accounting (manuals, procedures, internal
practices (units costs i.e. ‘average regulations, etc.). Perform interviews with
personnel costs’), the hourly rate must the responsible persons.
be calculated in accordance with the
beneficiary’s usual cost accounting b) Assess if the usual cost accounting has
practices for determining the hourly been set up based on objective criteria
rates of its personnel. The GA sets the regardless of the source of funding.
following conditions: a) the cost
accounting practices used must be c) Verify that the usual cost accounting
applied in a consistent manner, based was applied in other 5 non H2020
on objective criteria, regardless of the actions.
source of funding.
d) Verify that the usual cost accounting
practices have been correctly applied for
the H2020 action under review. (proper
calculation of the hourly rates and
allocation to staff)

e) Verify that the beneficiary declared in

Annex 2 of the GA including amendments
the use of personnel costs on the basis of
the usual accounting practices.

17
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. b) The hourly rate must be calculated 52 a) Verify that the hourly rate is calculated
6.2.A. using the actual personnel costs using the actual personnel costs recorded
1 recorded in the beneficiary’s accounts, in the beneficiary’s accounts. Budgeted or
excluding any ineligible cost or costs estimated figures are not costs actually
already included in other budget incurred and may only be acceptable as
categories. eligible components of the hourly rate if
1. they are relevant, i.e. clearly related to
personnel costs;
2. they are used in a reasonable way, i.e.
they do not play a major role in
calculating the hourly rate;
3. they correspond to objective and
verifiable information, i.e. their basis is
clearly defined and the beneficiary can
show how they were calculated.

If the budgeted or estimated figures

represent less than 5% of the declared
unit cost, it is considered that they do not
play a major role and can be accepted. If
the budgeted or estimated component is
higher than 5%, then it needs to be
compared with the actual costs.
1. If the actual costs cannot be
determined the budgeted component will
be considered ineligible. OR
2. If the actual costs can be determined,
adjustment will be proposed only if there
are negative adjustments in the favour of
the EC / AGENCY / JU, due to the use of
the budgeted elements higher than 5%
compared to the declared unit cost.
53 a) Exclude any cost considered ineligible
by the Commission but included in the
beneficiary’s usual accounting practices
when calculating the personnel costs for
the action.

b) Exclude from the calculation of the

personnel costs for the action the costs
that are already included in other budget
categories (double funding of the same
costs). Pay special attention to
components of indirect nature which may
be included in the pool of costs used to
calculate the hourly rate charged to the
H2020 action.
Art. c) Personnel costs on the basis of the 54 Verify if the calculation of the hourly rate
6.2.A. usual accounting practices (average was based on the number of annual
1 personnel costs): the hourly rate must productive hours in accordance with one
be calculated using the number of of the three methods allowed by the
annual productive hours. grant. Follow the procedures related to
productive hours from section
"Employees".

18
A.1 Employees (or equivalent)
GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. Personnel costs for H2020 actions are 55 a) Verify that the personnel costs per
6.2.A.1 calculated (for each person assigned person are calculated using the following
to the action, including persons formula: Hours Worked (time records) x
working exclusively on the action) as Hourly Rate (EUR/Hour) + Additional
follows: Remuneration (only for non-profit legal
Hours Worked (time records) x Hourly entities)
Rate (EUR/Hour) + Additional
Remuneration (only for non-profit b) Verify that the Beneficiary used the
legal entities) same option for the hourly rate (annual or
monthly) for all personnel (per staff
The calculation will differ (per type of category/type) in all H2020 audited
beneficiary/employee) depending on projects in a given financial year (or fiscal
the remuneration practices of the year if the beneficiary chose that option).
beneficiary:
Case 1: beneficiaries declaring
personnel costs as actual costs
Case 1A: employee whose
remuneration is not project-based (i.e.
same remuneration, regardless if they
are involved or not in specific projects)
Case 1B: employee whose
remuneration is project-based (i.e.
different remuneration levels,
depending on whether they work in
specific projects or not)
Case 2: beneficiaries declaring
personnel costs as unit costs in
accordance with the usual cost
accounting practices (average
personnel costs).
Art. For case 1A beneficiaries (actual 56 a) If the Beneficiary calculates the hourly
6.2.A.1 costs, not project-based rate per full financial year, verify that is
remuneration): calculated for each person as follows:
The beneficiary must calculate, for {actual annual personnel costs (excluding
each employee, the hourly rate to be additional remuneration) for the person
charged to the action by using one of divided by number of annual productive
the following methods: hours}.
- per full financial year (main The rate must be calculated by full
method): single hourly rate for each financial year (i.e. the 12-month period
person for each full financial year covered by the annual accounts of the
- per month (alternative method): one entity).
hourly rate for each person for each
month (i.e. 12 hourly rates per person b) If the Beneficiary calculates the hourly
for each financial year). rate month, verify that is calculated for
Each beneficiary may choose any of each person as follows:
the two options. However, the option {actual monthly personnel costs (excluding
chosen must be applied during the full additional remuneration) divided by
financial year to all its personnel in all {number of annual productive hours/12}}.
H2020 grants. If the beneficiary wants The rate must be calculated for each
to change option, it can do so for the month.
next financial year (for all type of The monthly personnel costs may include
personnel in all its H2020 grants). only eligible personnel costs.

19
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. For case 1B beneficiaries (actual 57 a) Verify that the Beneficiary calculate two
6.2.A.1 costs, project-based reference hourly rates ("action reference"
remuneration): and "national projects reference") and
The beneficiary must first find out, for compare them:
each employee, if the remuneration it If the action reference is equal or below
is paying is all basic remuneration or the national projects reference, the
contains also additional remuneration. remuneration is all basic remuneration. If it
To do this, the beneficiary must is higher, the exceeding part is additional
calculate two reference hourly rates: remuneration and must be taken out for
- reference rate for the work on the the calculation of the hourly rate to be
H2020 action (‘action reference’) charged to the action.
and - For the action reference verify that the
- reference rate for the usual hourly rate (either annual or monthly) is
remuneration practice for national calculated based on the remuneration paid
projects (‘national projects reference’). to the employee for his/her work in the
H2020 action.
For the action reference: the - For the national projects reference verify
beneficiary must calculate an hourly that the hourly rate is calculated following:
rate (either annual or monthly) based ___*_national regulatory requirement
on the remuneration paid to the ___*_internal rules, compliant with usual
employee for his/her work in the accounting practice.
H2020 action. If those amounts were actually paid at
least once before the submission of the
For the national projects reference: H2020 proposal and comply with the
the beneficiary must calculate an general eligibility criteria or, if none of the
hourly rate based on either: above is applicable:
-_national regulatory requirements ___*_the average remuneration of the
-_internal rules, compliant with usual employee in the previous financial year
accounting practice excluding remuneration paid for work in
Or, if none of the above is applicable: H2020 actions (considering that comply
-_the average remuneration of the with the general eligibility criteria). The
employee in the previous financial calculation must exclude both amounts
year excluding remuneration paid for and hours related to the EU actions in
work in H2020 actions. which the individual participated.

20
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. For case 2 unit costs in 58 Verify that the Beneficiary's personnel unit
6.2.A.1 accordance with the usual cost costs are calculated in accordance with the
accounting practices (average usual cost accounting practices, provided
personnel costs) that are:
The beneficiary can use the hourly - applied in a consistent manner, based on
rate(s) that it uses normally (usual objective criteria, regardless the source of
cost accounting practices) as average funding.
personnel costs, provided that: - calculated using actual personnel costs
- the cost accounting practices are recorded in the Beneficiary's accounts,
applied in a consistent manner, based excluding any ineligible costs or costs
on objective criteria, regardless of the already included in other budget categories
source of funding and
- the hourly rate is calculated using - using one of the three option provided in
the actual personnel costs recorded in the MGA for the number of annual
the beneficiary’s accounts, excluding productive hours.
any ineligible cost or costs already
included in other budget categories Budgeted or estimated elements used to
and calculate the hourly rate can only be
- the hourly rate is calculated using accepted if they:
one of the three options provided in - are relevant, i.e. clearly related to
the MGA for the number of annual personnel costs
productive hours (e.g. option 3 - are used in a reasonable way (i.e. do not
‘standard annual productive hours’). play a major role in calculating the hourly
The beneficiary must consistently rate)
apply its usual cost accounting - correspond to objective and verifiable
practices, based on objective criteria information (i.e. their basis is clearly
that must be verifiable if there is an defined and the beneficiary can show how
audit. It must do this no matter who is they were calculated).
funding the action.

21
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. Personnel costs are eligible, a) if 59 a) Review the employment contracts,
6.2.A.1 they are related to personnel working collective labour agreement (or equivalent
for the beneficiary under an appointing acts) to verify if the persons are
employment contract (or equivalent personnel working for the beneficiary or
appointing act) and b) assigned to the whether they are seconded from another
action (‘costs for employees (or organisation. For the duration of the action
equivalent)’). c) They must be limited cross check the information with the
to salaries (including during parental payroll records.
leave), social security contributions,
taxes and other costs included in the b) Verify if the person is assigned to the
remuneration, if they arise from action. Time records compliant with the
national law or the employment requirements of the H2020 Model Grant
contract (or equivalent appointing act). Agreement would suffice to confirm that a
Equivalent appointing act’ means the person is "specifically assigned to the
appointing acts of civil servants (who action". Please refer to the audit tests in
do not sign employment contracts but respect of time recording. If that is not
receive official nominations for their possible, perform alternative procedures to
posts) verify that the person is assigned to the
action. Alternative procedures to be
considered: Review contracts (or
equivalent), job description, internal written
instructions, organisation chart or other
evidence to support the management
decision that the personnel was assigned
to the action. Verify that the persons were
not supposed to fully work for another
action/ project.

c) Verify that the salaries (including during

parental leave), social security
contributions, taxes and other costs
included in the remuneration arise from
national law or the employment contract,
collective labour agreement (or equivalent
appointing act).

22
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. Direct personnel costs: Employees (or 60 a) Review the employment contracts and
6.2.A.1 equivalent) covers (and is limited to): personnel costs components in order to
- basic remuneration (i.e. the identify the "basic remuneration" and the
payments for the employee's normal "additional remuneration".
work and participation in projects —
up to what is the beneficiary's usual b) Verify that the basic salary is limited to:
remuneration practice for national the salary stated on the beneficiary’s
projects) payroll; social security contributions; taxes
and, in addition: included in the remuneration and other
- for non-profit legal entities: costs included in the remuneration.
additional remuneration (i.e. extra
payments made for the participation For exceptions verify if they are eligible as
in projects — above the beneficiary's bonuses within "basic remuneration" or as
usual remuneration practice for part of "additional remuneration".
national projects).

Both basic remuneration and

additional remuneration do not only
cover the payment itself (salary or
bonus), but also the social security
contributions (mandatory employer
and employee contributions), taxes
included in the remuneration (e.g.
income tax) and other costs and
payments included in the
remuneration (e.g. a fee paid by the
beneficiary for a complementary
health insurance scheme for the
employee).

National projects are to be understood

in the large sense, meaning all types
of projects funded under any type of
national (public or private) funding
scheme (including projects co-
financed by EU funds that are
managed by the Member States, e.g.
regional funds, agricultural and
fisheries funds).

23
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. Eligibility conditions for basic 61 a) Verify that the general conditions for
6.2.A.1 remuneration: costs to be eligible (i.e. incurred during the
a) fulfil the general conditions for action duration, necessary, etc.; see Article
costs to be eligible (i.e. incurred during 6.1(a) and (b)) are fulfilled. Payments of
the action duration, necessary, etc.; dividends to employees (profit distribution)
see Article 6.1(a) and (b)) are ineligible under Article 6.5(a). Refer to
Payments of dividends to employees section "General".
(profit distribution) are NOT eligible
under Article 6.5(a)(i). However, b) Identify if there are components of
bonuses based on the overall financial remuneration that were granted with
performance of the organisation (e.g. reference to commercial targets and/or
profitability or surplus) may be fund raising activities. Example (not
accepted, if they fulfil the conditions eligible because linked to fund raising
set out below, i.e. as part of the usual target): A premium paid as a reward for
remuneration practices for national having obtained a specific grant is not
projects and thus eligible as basic eligible.
remuneration.
Any part of the remuneration which is
based on commercial targets or fund
raising targets is NOT eligible
(because neither incurred in
connection with the work described in
Annex 1 of the action nor necessary
for its implementation).

Art. b) be paid in accordance with national 62 Verify if the basic remuneration is paid in
6.2.A.1 law, the collective labour agreement accordance with the national law, the
and the employment collective labour agreement and the
contract/equivalent appointing act employment contract/equivalent
appointing act.

24
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. c) exclude arbitrary bonuses (i.e. 63 a) Verify that the amount to be actually
bonuses which are not part of the paid as bonus is determined on the basis
6.2.A.
beneficiary's usual remuneration of conditions which are established and
1 practices and/or which are not based documented in the internal regulations of
on objective conditions). the beneficiary (including decisions of a
board of directors).

b) Verify if the conditions are "objective",

based on predefined criteria, merits,
seniority levels, or other objectively
defined conditions. The bonus should NOT
be paid to the employee at the sole
discretion of the manager (arbitrary
complement).

c) Verify that the usual remuneration

practices in respect of bonuses of the
Beneficiary have been set up based on
objective criteria regardless of the source
of funding; in particular that they do not
refer only to EU grants.

d) Verify that bonuses were calculated in

accordance with the usual remuneration
practice of the Beneficiary

e) Verify that the requirements regarding

social charges and other taxes in relation
to the bonuses were correctly calculated,
incurred and paid in accordance with
national law (or equivalent act).
Art. ‘Additional remuneration’ means any 64 a) Verify that the Beneficiary is a non-
6.2.A.1 part of the remuneration which profit legal entity by reviewing its legal
exceeds what the person would be registration.
paid for time worked in projects
funded by national schemes. b) Review the personnel costs claimed and
Additional remuneration for personnel review if the persons worked the full year,
assigned to the action is eligible up to if they work full time or if they work
the following amount: exclusively for the action. Review contracts,
(a) if the person works full time and time records and other supporting
exclusively on the action during the documentation.
full year: up to EUR 8 000;
(b) if the person works exclusively on c) Calculate and take into consideration the
the action but not full-time or not for maximum eligibility threshold for
the full year: up to the corresponding additional remuneration for each person
pro-rata amount of EUR 8 000, or and for each year considering their working
(c) if the person does not work patterns.
exclusively on the action: up to a pro-
rata amount calculated as follows: d) Verify that the requirements regarding
{{EUR 8 000 divided by the number of social charges and other taxes in relation
annual productive hours}, multiplied by to the additional remuneration were
the number of hours that the person correctly calculated, incurred and paid in
has worked on the action during the accordance with national law (or
year}. equivalent act).

25
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. Eligibility conditions for additional 65 Verify for additional remuneration that:
6.2.A.1 remuneration (in addition to the
conditions for basic remuneration): a) the general conditions for costs to be
- be a non-profit legal entity eligible (i.e. incurred during the action
- be paid for the performance of duration, necessary, etc.; see Article 6.1(a)
additional work or different expertise and (b)) are fulfilled. Refer to section
than his/her usual tasks "General".
This is usually the case, since
additional remuneration aims b) Identify if there are components of
precisely to reimburse the additional remuneration that were granted with
work/expertise that is required for EU reference to commercial targets and/or
and international projects. fund raising activities.

c) Verify that the work carried out (or

expertise used) to be paid as additional
remuneration is different from the
standard work or expertise (defined in the
employment contract/ equivalent
appointing act and covered by the
standard remuneration package).

Art. Eligibility conditions for additional 66 a) Verify that the additional remuneration
6.2.A.1 remuneration: is determined on the basis of criteria which
- be consistently applied whenever the are established and documented in the
same kind of work or expertise is internal regulations of the beneficiary (e.g.:
required and regardless of the source remuneration practices).
of funding used
The additional remuneration may not b) Verify if the criteria are "objective" and
differ according to where the funds are related to the additional work or
come from. In particular, it cannot be expertise. The additional remuneration
set up for actions funded by a specific should NOT be paid to the employee at the
donor; additional remuneration sole discretion of the manager (arbitrary
schemes that are applicable only to complement).
EU projects are not acceptable.
Also, they may not be subject to c) Verify that the usual remuneration
budget availability (i.e. only to be paid practices in respect of additional
if there is remaining funds in the remuneration of the Beneficiary have been
project budget). set up based on objective criteria
The additional remuneration does not regardless of the source of funding.
have to be the same for all persons
working in the same project (provided d) Verify that the additional remuneration
that objective criteria are used to is not subject to budget availability (i.e.
determine the differences). only to be paid if there is remaining funds
in the project budget).

e) Verify the beneficiary’s usual

remuneration practices for additional
remuneration have been consistently
applied whenever the same kind of work or
expertise is required, by reviewing 5 non-
EU transactions.

f) Verify that the additional remuneration

has been calculated in accordance with the
usual remuneration practice of the
Beneficiary.

26
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. Calculation of the annual 67 a) Obtain from the Beneficiary
6.2.A.1 productive hours, three options: explanations about the calculation method
In principle, the same option (1, 2 or for the annual productive hours among the
3) must be applied to all personnel three options available. If the Beneficiary is
working in H2020 actions. However, using monthly hourly rates it is not allowed
the beneficiary may use different to use the option individual productive
options for different types of hours.
personnel, if:
- the same option is applied at least b) Verify that the option chosen is
per group of personnel employed consistently applied per group of personnel
under similar conditions (e.g. same employed under similar conditions (e.g.
staff category, same type of contract, permanent employees, in-house
etc.) and employees, temporary employees,
- the options are applied consistently seconded from third party, etc.).
(e.g. the choice of the option is not Consistency is to be verified among the
changed ad-hoc for specific staff declared to the H2020 actions.
employees).
The beneficiary must keep the same
option(s) for the full financial year. It
can only change its option(s) for the
next financial year.

Art. (Option 1) 1720 fixed hours is the 68 a) Obtain from the Beneficiary the full-
6.2.A.1 number of productive hours accepted time equivalent of each person for each
for full-time employees (and it is pro- financial or fiscal year. Review the
rata for employees working part-time employment contracts to verify that the
or working only part of the year for full time equivalent used to compute the
the beneficiary). pro-rata to be applied to the 1720 hours
ONLY actual time spent on parental has been correctly calculated. Identify if
leave (maternity and parental leave) there are persons, not working full time for
may be deducted from the 1720 fixed the Beneficiary or not working for the full
hours. NO other leave (e.g. sick leave, year for the Beneficiary and verify the
special leave, annual leave, etc.) can correct application of the 1720 hours
be deducted. option (which correspond to a full time
NO overtime may be added to the employment contract).
1720 fixed hours
b) Obtain the beneficiary's internal rules on
maternity/parental leave. Verify that is not
If the beneficiary calculates monthly deducted other leave than actual time
hourly rate, time spent on parental spent on parental leave.
leave can NOT be deducted from the
annual productive hours. If the Beneficiary calculates monthly
hourly rates verify that productive hours of
143.33 hours per month (1720 hours/12
months) have been used in the
calculations. The pro-rata effect as verified
in the procedure above has to be also
taken into consideration.

27
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. (Option 2) Individual annual 69 For each financial or fiscal year:
6.2.A.1 productive hours: The number of - If the Beneficiary calculates monthly
hours is calculated on the basis of the hourly rates and uses individual annual
‘annual workable hours’ of the productive hours option, the eligible cost
employee (i.e. the total number of will need to recalculate by the auditor
hours for which an employee is using revised productive hours of 143.33
working for the beneficiary, including hours per month (1720 hours/12 months),
the overtime worked and absences as the individual productive hours option is
(such as sick leave or other types of not available for Beneficiaries who
special leave). calculate monthly hourly rates.
‘Annual workable hours’ means the
period during which the personnel - If the Beneficiary does not use monthly
must be working, at the employer’s hourly rates, perform the procedures
disposal and carrying out his/her below:
activity or duties under the a) Trace the workable hours to supporting
employment contract, applicable documentation.
collective labour agreement or b) Trace the deductions for Saturdays and
national working time legislation. Sundays; annual leave and other leaves
Therefore, annual leave entitlements (e.g. parental/maternity) and public
have to be removed to calculate the holidays to supporting documentation.
annual workable hours. c) Trace the overtime and absences to
However, if the employment contract supporting documentation. (e.g.: time
allows end-of-year transfers for leave records, human resources databases, etc.).
entitlements (i.e. the days not taken d) Recompute the annual productive hours
one year can be taken the next one; based on provided documentation.
days not taken are not paid out), the
beneficiary may opt for deducting
instead actual time of annual leave (if
this is done consistently throughout
the years).

Under option 2 (individual): the

beneficiary must deduct all leaves (i.e.
actual time on sick leave, parental
leave or special leave etc.) to
calculate the annual productive hours.
All overtime worked (paid or unpaid)
must be added to the annual workable
hours to calculate the annual
productive hours
Option 2 can NOT be used for
monthly hourly rates.
This option can NOT be used if the
employment contract, collective labour
agreement or national law does not
allow determining the number of
individual annual workable hours.

28
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. (Option 3) Standard annual 70 a) Determine which is the standard annual
6.2.A.1 productive hours: workable hours of the Beneficiary for each
The number of productive hours is financial or fiscal year. Perform this
calculated on the basis of the procedure at the same level of detail as
‘standard annual productive hours’ the Beneficiary is calculating the standard
generally applied by the beneficiary annual productive hours (entity as a whole,
for its personnel, in accordance with per category of personnel, per cost centre,
its usual cost accounting practices. etc.) To do this review the relevant
The standard annual productive hours employment contracts, collective labour
may be calculated for the entity as a agreement, the national law on working
whole, per category of personnel, per time categories and trace the deductions
cost centre, etc. for Saturdays and Sundays; annual leave;
The beneficiary may include or and public holidays to supporting
exclude certain activities (e.g. general documentation.
training, general meetings etc.) when
calculating the standard annual b) Verify that the number of standard
productive hours, if this is in line with annual productive hours is at least 90% of
its usual cost accounting practices. the standard annual workable hours.
The number of standard annual
productive hours is at least 90% of c) Obtain an understanding of the usual
the "standard annual workable hours". cost accounting practice by reviewing the
necessary supporting documentation
Under option 3 (standard): the (manuals, procedures, internal regulations,
standard annual productive hours etc.). Perform interviews with the
defined by the beneficiary normally responsible persons.
take into account the standard time of
absence in the organisation. However, d) Verify that the usual cost accounting
the beneficiary may deduct on top the has been set up based on objective criteria
actual time spent on parental leave regardless of the source of funding.
(maternity and parental leave) by the
individual employee. e) Verify that the usual cost accounting
was applied in other 5 non H2020 actions.
The standard annual productive hours
defined by the beneficiary normally f) Verify that the exclusion of certain
take into account the standard activities (e.g. general training, general
overtime hours in the organisation (if meetings etc.) from the productive hours
any). are mentioned/ approved in the usual cost
accounting practices.

g) Verify that the mentioned/ approved

exclusions from the productive time are
computed in accordance with the
methodology defined in usual cost
accounting of the Beneficiary.

h) Verify that the usual cost accounting

practices have been correctly applied for
the H2020 action under review.

29
A.2 Natural persons with direct contract
GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. A.2 The costs for natural persons working 71 Arrange interviews with the beneficiary
6.2.A.2 under a direct contract with the and review the list of persons selected
beneficiary other than an employment for testing and identify natural persons
contract are eligible personnel costs, if: working under a direct contract. Perform
(a) the person works under conditions the procedures listed in this section for
similar to those of an employee (in this type of personnel costs. For the
particular regarding the way the work is sake of simplicity from now onwards
organised, the tasks that are performed the term "natural person" will be used in
and the premises where they are this section to refer to natural persons
performed); working under a direct contract.
(b) the result of the work carried out
belongs to the beneficiary (unless
exceptionally agreed otherwise), and
(c) the costs are not significantly different
from those for personnel performing
similar tasks under an employment
contract with the beneficiary.

This budget category covers typically the

costs for in-house consultants and similar
persons
(i.e. self-employed natural persons; not
one-person companies) that worked on
the action for the beneficiary under
conditions similar to those of an
employee, but under a contract which is
NOT legally the same as for employees. It
regards, in particular, contracts qualified
as quasi-subordinate work contracts under
national law when the conditions under
which the work is carried out are similar to
those of an employee.

Art. Costs for natural persons working under a 72 a) If the beneficiary declared the costs
6.2.A.2 direct contract may be declared as actual for natural persons on the basis of unit
costs or on the basis of unit costs in costs in accordance with the usual
accordance with the usual cost accounting accounting practices follow the relevant
practices (i.e. ‘average personnel costs’; procedures in respect of unit costs
see Article 5.2(a)). already included in the section
"Employees".

b) If the Beneficiary claimed actual

costs perform the procedures from this
section.

c) Obtain information if the natural

persons declared on the EU action have
been working before for the Beneficiary
based on a different type of contract.

d) Verify if the remuneration has been

artificially increased for participation in
the EU action.

30
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. The costs must comply with the following 73 a) Verify that the general conditions for
6.2.A.2 conditions for eligibility: costs to be eligible (i.e. incurred during
a) fulfil the general conditions for costs to the action duration, necessary, etc.; see
be eligible (i.e. incurred/used during the Article 6.1(a) and (b)) are fulfilled. Refer
action duration, necessary, linked to the to section "General".
action, etc.; see Article 6.1(a) and (b)).
b) there must be a direct contract between b) Review the contracts and verify that
the natural person (individual) and the the natural persons have a contract with
beneficiary. The contract cannot be with a the Beneficiary governed by labour law
third party legal entity (e.g. a temporary not applicable to employees. Verify that
work agency). the contracts are with the natural
persons and not companies, including
Staff provided by temporary work temporary work agencies.
agency
A contract with a temporary work agency Enquire if any of the selected
for the provision of staff qualifies employees is provided by a temporary
typically as a purchase of services (unless work agency.
the temporary work agency carries out If this is the case, reclassify the cost to
directly some task of the action — in "D.3 other goods and services" or "B.
which case it can be considered as subcontracting" and carry out the
subcontracting). Thus, although NOT related testing for each cost category.
eligible as personnel costs, the costs can
be charged under other budget categories
(i.e. D.3 other goods and services or B.
subcontracting), if they comply with the
eligibility conditions (especially best value
for money and no conflict of interest; see
Articles 10 and 13).

31
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. c) The person must work under conditions 74 a) If there is a telework agreement in
6.2.A.2 similar to those of an employee (Similar place, perform the procedures related to
does not mean equal — The working Teleworking from the section "Specific
conditions of the person do NOT have to cases" in order to verify if it can be
be exactly the same that those of an accepted. Certain research work requires
employee, but overall similar), in permanent persons to work off the
particular: premises of the employer at a research
- the beneficiary must organise and site. This is not considered teleworking
supervise the work of the person in a way but a usual work activity. Take this into
similar to that of its employees. account and corroborate information
- the beneficiary must be able to ensure from time records, reports/results from
reliable time recording (for the hours that work done, research logs etc.
the person works for the action).
- the person is subject to similar presence b) Verify that the person works under
requirements as the employees. the beneficiary’s instructions on the
beneficiary’s premises. Perform
interviews, review contracts, lab logs,
minutes of meetings, if available review
presence system where the beneficiary
keeps track when its personnel enter
and leave the building, perform
searches in the internet. Check if the
natural person was living in another
country or distant city; or also working
at the same time for another entity in
another city.

c) Verify that the beneficiary decides,

designs and supervises all work in a
similar way that its own employees.
Review contract and other supporting
documentation.

d) Verify that the natural person reports

to the beneficiary. Review emails or
other supporting documentation.

For exceptions verify compliance with

the eligibility criteria for ‘purchase of a
service’ (see Article 10) or as a
‘subcontracting cost’ (see Article 13).
Art. d) the result of the work carried out 75 Review the contract and verify if there is
6.2.A.2 (including patents or copyright) must in a clause stipulating that the work
principle belong to the beneficiary. carried out, including any resulting
If (exceptionally) they belong to the patents or copyright belongs to the
person, the beneficiary must (just like for beneficiary.
employees) obtain the necessary rights
from the person (transfer, licences or
other), in order to be able to respect its
obligations under the GA (see Article 26.3).

32
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. e) not be significantly different from costs 76 a) Verify that the hourly rates of natural
6.2.A.2 for employees performing similar tasks. persons are not significantly different
The remuneration must be based on from the hourly rates of personnel
working hours, rather than on delivering performing similar tasks and
specific outputs/products. responsibilities under an employment
contract with the beneficiary. A
difference of up to 50% can be
accepted, if justified by the beneficiary.
If there are no employees in the
company with similar tasks report that
this test was not applicable. b) Verify
that the remuneration is based on
working hours, rather than on delivering
specific outputs/products.

Art. Cost of natural persons working under a 77 Verify that the beneficiary used for the
6.2.A.2 direct contract for a beneficiary must be hourly rate one of the following options:
calculated according to the same formula a) the hourly rates specified in the
(i.e. hourly rate multiplied by the number contract;
of actual hours worked on the action). b) the global amount specified in the
However, for the hourly rate, the contract divided by the number of hours
beneficiaries must use one of the to be worked under that contract
following options: c) the global amount specified in the
a) if the contract specifies an hourly rate: contract divided by the pro-rate of 1720
this hourly rate must be used hours.
b) if the contract states a fixed amount
for the services of the natural person and
the number of hours to be worked: the
global amount must be divided by the
number of hours to be worked.
c) If the contract fixes only a global
amount and does not specify the number
of hours to be worked:
the global amount for the work must be
divided by the pro-rata of 1 720 annual
productive hours which corresponds to the
duration of the contract over the financial
year.

33
A.3. Seconded personnel (against payment)
GA General procedure to be Spec.
Condition to be checked N.
Art. performed Proc.
Art. This budget category covers the costs of 78 Arrange interviews with the
6.2.A.3 persons that worked on the action and that beneficiary and review the list of
were seconded by a third party as an "in kind persons selected for testing and
contribution against payment" (see article identify temporary transfers of
11). seconded persons. Perform the
What not? Persons provided by a temporary procedures listed in this section for
work agency, secondment of staff between this type of personnel costs.
beneficiaries (or linked third parties) in the
same grant or secondment by a third party
free of charge.
Art. 11 The beneficiaries may declare costs related 79 a) Verify that the Third Parties and
to the payment of in-kind contributions as their contributions were foreseen in
eligible (see Article 6.1 and 6.2), up to the Annex 1 or approved by the EC /
third parties’ costs for the seconded persons, Agency / JU.
contributed equipment, infrastructure or
other assets or other contributed goods and
services. b) Verify that the beneficiaries
The third parties and their contributions must limited the costs declared for the
be set out in Annex 1. The payment of in-kind contributions up
[Commission][Agency] may however approve to the costs incurred by the third
in-kind contributions not set out in Annex 1 parties for the seconded persons,
without amendment (see Article 55), if: corresponding to the time the person
- they are specifically justified in the periodic has worked for the action. Obtain the
technical report and supporting documents that
- their use does not entail changes to the demonstrate the actual cost borne by
Agreement which would call into question the the Third Party (e.g.: payslips,
decision awarding the grant or breach the accounting entries, etc.). Please note
principle of equal treatment of applicants. that if the seconded person is
The beneficiaries must ensure that [the working in the premises of the third
Agency,] the Commission, the European Court party the direct costs actually
of Auditors (ECA) and the European Anti- incurred by the third party may be
Fraud Office (OLAF) can exercise their rights increased by a flat rate of 25% on
under Articles 22 and 23 also towards the these costs.
third parties.
Art. Costs for persons seconded by a third party 80 If the beneficiary declared the costs
6.2.A.3 may be declared ONLY as actual costs. for persons seconded by a third party
using actual costs, perform the
procedures in respect of actual costs
from the section "Employees".

Art. The costs must comply with the following 81 Perform the procedures in respect of
6.2.A.3 conditions for eligibility: Article 6.1 (a) and (b) from the
a) fulfil the general conditions for costs to be section "General"
eligible (i.e. incurred/used during the action
duration, necessary, linked to the action, etc.;
see Article 6.1(a) and (b))

34
 GA General procedure to be Spec.
Condition to be checked N.
Art. performed Proc.
Art. b) The person must be seconded. 'Seconded' 82 Review the secondment contracts, or
6.2.A.3 means the temporary transfer of personnel other equivalent supporting
from a third party to the beneficiary. The documentation (decisions,
seconded person is still paid and employed engagements) to document the
by the third party, but works for the temporary transfer of the seconded
beneficiary. S/he is at the disposal of the persons. Verify that the seconded
beneficiary. Example: A researcher in a public personnel work for the beneficiary.
research centre is seconded to work in a Verify if there is a clause saying that
university that is a beneficiary in a GA. the seconded personnel are at the
A secondment does not necessarily require disposal of the beneficiary.
the seconded person to work at the
beneficiary’s premises, although this is what
usually happens.
Art. c) the beneficiary must reimburse the costs 83 a) Verify that the beneficiary
6.2.A.3 to the third party (i.e. not for free) reimbursed the costs to the third
party (i.e. not for free).

b) Compare the costs declared for

the seconded persons with the
amount paid to the third party.
Art. d) fulfil the additional cost eligibility 84 Perform the procedures listed at no 1
6.2.A.3 conditions set out in Article 11.1. in this section.
Art. The same rules for calculation apply as in 85 a) In addition to the procedures from
6.2.A.3 point 1.1.4. the section "Time recording"
corroborate information from the
time records of the third party and
the time records of the Beneficiary to
identify any contradictions.

b) Perform the procedures for hourly

rate, remuneration and productive
hours from the section "Employees".

35
A.4 SMEs owners &
A.5 Natural persons not receiving a salary
GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. A.4 Costs of owners of beneficiaries that 86 Arrange interviews with the beneficiary ERA-
6.2.A.4 are small and medium-sized enterprises and review the list of persons selected NET
/A.5 (‘SME owners’), who are working on the for testing and identify SMEs owners Cof
action and who do not receive a salary not receiving a salary and natural
are eligible personnel costs, if they persons not receiving a salary. Perform
correspond to the amount per unit set out the procedures listed in this section for
in Annex 2a multiplied by the number of this type of personnel costs. For the
actual hours worked on the action. sake of simplicity from now onwards
A.5 Costs of ‘beneficiaries that are the term "SME owner/natural person"
natural persons’ not receiving a salary are will be used in this section to refer to
eligible personnel costs, if they SMEs owners not receiving a salary and
correspond to the amount per unit set out natural persons not receiving a salary.
in Annex 2a multiplied by the number of
actual hours worked on the action.
Art. These budget categories cover the costs 87 a) Review the payroll, contracts and ERA-
6.2.A.4 of SME owners and beneficiaries that are other documentation and verify that NET
/A.5 natural persons which work on the action SME owner/natural person works on the Cof
but don't receive a salary. This includes action but does not receive a salary.
SME owners who are
remunerated/compensated for their work b) If the SME owner receives a salary
for the SME by any other means than a (registered as such in the accounts of
salary (for example, dividends, service the SME), verify that this salary does
contracts /other non-employment not correspond exclusively to the
contracts between the company and the management of the SME and is
owner). What not? SME owners who therefore not linked to the action.
receive a salary (registered as such in the Review contract, time records and other
accounts of the SME) cannot declare evidence.
personnel costs under this budget
category, unless s/he can show that this c) Verify if there is change in the
salary corresponds exclusively to the remuneration status of the SME
management of the SME (and is therefore owner/natural person during the course
not linked to the action). (In this case, the of the action.
salary for the management of the SME
cannot be declared.) If the remuneration
status of the SME owner changes during
the course of the action, the beneficiary
has to request an amendment (see Article
55), in order to change the form of costs
used (e.g. from unit cost to actual costs).
Example: A GA was signed in 2014 with
an SME whose owner does not receive a
salary. The action’s personnel costs are
calculated based on the unit cost set out
in Annex 2. In 2016, the SME starts
paying the owner a salary for his/her
work. From that moment on, any costs
charged to the Horizon 2020 action
require an amendment to the GA to
remove the unit cost and to allow the
SME owner to charge personnel costs
based on his/her salary. The SME may no
longer use unit costs to declare the costs
of its owner.

36
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. These costs must be declared on the 88 Verify that the correct specific rate for SME-
6.2.A.4 basis of the unit cost (hourly rate) fixed each individual has been used. Ph2
/A.5 by Commission Decision C(2013) 819718
and set out in Annex 2 and 2a of the GA. ERA-
The precise unit cost is not pre-fixed by NET
the Decision; the ‘amount per unit’ (hourly Cof.
rate) must be calculated for each
individual before signature of the GA
according to the following formula:
Amount per unit = {{EUR 4,650/143 hours}
multiplied by {country-specific correction
coefficient of the country where the
beneficiary is established}} The country-
specific correction coefficient is the one
set out in the Main Work Programme —
MSCA in force at the time of the call.
Example: A German SME owner not
receiving a salary will calculate the hourly
rate as follows: EUR 4.650/143 * 98.8% =
EUR 32,13 /hour. In practice, the
declaration of costs for SME owners and
beneficiaries that are natural persons is
very simple and almost completely
automatised: The beneficiaries must only
indicate the number of hours worked on
the action and the costs are then
automatically calculated by the IT system.
Art. The costs must comply with the following 89 Verify that the general conditions for ERA-
6.2.A.4 conditions for eligibility: costs to be eligible (i.e. incurred during NET
/A.5 (a) fulfil the general conditions for unit the action duration, necessary, etc.; see Cof
costs to be eligible (i.e. units used during Article 6.1(a) and (b)) are fulfilled. Refer
the action duration, necessary, linked to to section "General".
the action, correct calculation etc.; see
Article 6.1(b)).
(b) be declared for an owner of an
SME/beneficiary that is natural person,
who works on the action but does not
receive a salary. The owner may be
compensated by means such as
dividends, service contracts between the
company and the owner, etc.
The Commission / Agency may verify that
the beneficiary fulfils the conditions for
using this unit cost.
Art. They are calculated (automatically by the 90 a) Recalculate the declared costs for ERA-
6.2.A.4 IT system) as follows: SME owners/ natural persons. NET
/A.5 amount per unit (hourly rate; see Annex Cof
2a GA) x number of actual hours worked b) Verify that the total number of hours
on the action. declared in EU and Euratom grants for
Ceiling — The total number of hours a year (i.e. a financial year) is NOT
declared in EU and Euratom grants for an higher than 1720 hours.
SME owner for a year (i.e. a financial
year) can NOT be higher than 1 720.

37
A.6 Access to research infrastructure personnel costs
GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. This budget category covers the 91 Arrange interviews with the beneficiary SME-
6.2.A.6 personnel costs for access to and review the list of persons selected for Ph2
infrastructure activities, i.e.: costs for testing and identify the persons for who
employees (or equivalent) basic personnel costs for access to ERA-
remuneration and infrastructure activities have been NET
for non-profit legal entities: additional declared. Perform the procedures listed in Cof
remuneration; this section for this type of personnel
costs for natural persons working under costs.
a direct contract and costs of personnel
seconded by a third party against
payment.
Art. Personnel costs for providing trans- 92 a) If the beneficiary declared the costs for SME-
6.2.A.6 national or virtual access to research persons providing for access to Ph2
infrastructure may be declared as infrastructure activities perform the
actual costs or on the basis of unit costs procedures in respect of actual costs from ERA-
in accordance with the usual cost the section "Employees", "Natural Persons" NET
accounting practices (i.e. ‘average or "Seconded" depending on type of Cof
personnel costs’) (see Article 5.2(a)). personnel declared.

b) If the beneficiary declared the costs for

persons providing for access to
infrastructure activities using unit costs,
perform the procedures in respect of
Personnel costs on the basis of the usual
accounting practices from the section
"Specific Cases".
Art. Article 6.2 (1.5.3) The costs must 93 Verify that the general conditions for SME-
6.2.A.6 comply with the following conditions for costs to be eligible (i.e. incurred during the Ph2
eligibility: (a) fulfil the general action duration, necessary, etc.; see Article
conditions for costs to be eligible (i.e. 6.1(a) and (b)) are fulfilled. ERA-
incurred/used during the action duration, NET
necessary, linked to the action, etc.; see Cof
Article 6.1(a) and (b))
Art. (b) fulfil the specific conditions for costs 94 Perform the procedures from the section SME-
6.2.A.6 for employees (or equivalent), costs for "Employees", "Natural Persons" or Ph2
natural persons working under a direct "Seconded" depending on the type of
contract or costs of personnel seconded personnel costs claimed for access to ERA-
by a third party against payment infrastructure activities. NET
Cof

38
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. (c) be incurred for providing trans- 95 In addition to the procedures from the SME-
6.2.A.6 national or virtual access to research section "Time recording" verify that the Ph2
infrastructure personnel costs are incurred for providing
trans-national or virtual access to ERA-
research infrastructure. NET
Cof
For example:
1. preparation of the detailed access
activity information that must be included
in the periodic technical reports and/or the
assessment report;
2. the organisation of the assessment
carried out by the board of international
experts;
3. the operation of the research
infrastructure or installation;
4. logistical, technological and scientific
support for users e.g.: a helpdesk,
including ad-hoc user training;
5. preparatory and closing activities
needed to use the installation.
Art. The same rules for calculation apply as 96 a) For employees perform the procedures SME-
6.2.A.6 in points 1.1.4, 1.2.4 and 1.3.4. for hourly rate, remuneration and Ph2
productive hours from the section
"Employees". ERA-
NET
b) For natural persons working under a Cof
direct contract perform the procedures in
respect of point 1.2.4 from the section
"Natural Persons".

c) For personnel seconded by a third party

against payment perform the procedures
in respect of point 1.3.4 from the section
"Seconded"

Final General Control

Condition Spec.
GA
to be N. General procedure to be performed Proc.
Ref.
checked
97 In cases in which the procedures listed above have been carried out
successfully but the auditor, during the execution of these procedures,
came across facts and documents which put into question the
compliance of the costs with the eligibility criteria foreseen in the
H2020 grant agreement this information should be reported
accompanied with adequate supporting information.

39
B. SUBCONTRACTING
The subcontracting costs should be either :

1) clearly specified in Annex 1 in terms of nature and amount, thus known by the Commission when selecting
the action's proposal or
2) approved via an amendment to the Grant Agreement after its signature with (again) nature of the costs
and amount known by the Commission or
3) approved, on an exceptional basis, by the Commission by accepting the justifications provided by the
Beneficiary in the technical periodic reports.
In all three cases the Commission grants (or not) an approval based on clear information as regards the
nature of the subcontracting services, the respective estimated amounts and the circumstances that required
the use of subcontracting.

Since the Commission grants the approval based on an ex-ante assessment, the following eligibility criteria
are deemed to be complied with once the Commission's approval is granted:
1) the costs for subcontracting are necessary for the action;
2) the costs for subcontracting are reasonable, justified, economic, efficient and not reckless;
3) in case of approval on exceptional basis (point 3 above), the subcontracting is not entailing changes to the
Grant Agreement which would call into question the decision awarding the grant or breach the principle of
equal treatment of applicants.

The below procedures DO NOT cover PCP and PPI.

General Procedures
GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. The tasks to be implemented and the 1 Obtain the last version of Annex 1
13.1.1 estimated cost for each subcontract Description of Work of the audited
must be set out in Annex 1 Description Grant Agreement(s). Confirm that Annex
of Work of the audited Grant 1 Description of Work of the audited
Agreement(s). Grant Agreement(s) contains a
description of the tasks to be
subcontracted and estimated costs for
subcontracting.

Art. Subcontractors participate in the action 2 Compare the information from Annex 1
13.1.1 by carrying out action tasks for the Description of Work with the tasks
beneficiary. They are NOT beneficiaries subcontracted by the Beneficiary for
and therefore have no direct obligations which costs are declared. Confirm that
under the grant agreement (but their no material discrepancies exist both in
beneficiaries must ensure that they the nature of the subcontracting and in
comply with certain key obligations). terms of value.
Subcontract — For the purposes of the
GA, a ‘subcontract’ means the purchase
of goods, works or services that are
identified in Annex 1 as action tasks.
Art. Costs for subcontracting not foreseen in 3 Obtain the periodic technical report of
13.1.1 Annex 1 Description of Work of the the audited Grant Agreement(s).
audited Grant Agreement(s) were Confirm that the costs for
specifically justified in the periodic subcontracting which have not been
technical reports. foreseen in Annex 1 Description of Work
have been specifically justified in the
periodic technical reports of the action.

40
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. 4 Verify that there is a confirmation from
13.1.1 the EC/ AGENCY / JU services that the
costs for subcontracting not foreseen in
Annex I but justified in the periodic
technical reports are accepted by the
EC/ AGENCY / JU services.
Art. Costs must be actually incurred by the 5 Obtain from the Beneficiary the list of
6.1.a.(i) Beneficiary. items for which costs are declared in
the category Subcontracting.
Art. 6 Confirm that the total amount resulting
6.1.a.(i) from the list of items corresponds to
the amount declared in the financial
statement(s). For beneficiaries with
accounting established in other currency
than the euro first convert the total
amount resulting from the list of items
to euro by using the rate as specified in
Art.20.6 of the H2020 GA.
Art. 7 Select a sample from the list of items
6.1.a.(i) declared in the category Subcontracting
as follows:
1) If the total subcontracting costs are
below the planning materiality level (5%
of total costs declared) the item with
the highest value in the population
should be selected;
2) If the total subcontracting costs are
above the planning materiality level
(5% of total costs declared) then
2.a) if the population is less or equal
to 5 items, all items should be tested;
or
2.b) If the population is more than 15
items select for testing a maximum of
15 items.
Select for testing all the items with a
value higher or equal to 10% of the
subcontracting costs declared. Add
randomly selected items until 50%
coverage of the subcontracting costs is
achieved or the total maximum number
of 15 items is reached. The procedures
below are to be carried out on the
sampled items only. The item is defined
as one contract.
Art. 8 If systemic or recurrent errors are
6.1.a.(i) identified request the Beneficiary to
recalculate the declared costs for the
action by removing the effect of the
systemic or recurrent errors for the
whole population. Verify the accuracy
and reliability of the recalculation
performed by the Beneficiary.

41
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. 9 Obtain from the Beneficiary the
6.1.a.(i) underlying documentation (invoices,
debit notes, credit notes, proofs of
delivery, etc.) for each sampled item.
Reconcile in monetary terms each item
to the specific underlying document
(invoices, debit notes, etc.).

Art. 10 Ensure that the underlying documents

6.1.a.(i) are addressed to the Beneficiary.
Art. 11 Confirm that the accounting documents
6.1.a.(i) justifying the costs for subcontracting
(invoices, debit notes, credit notes, etc.)
are recorded in the Beneficiary's
statutory accounting books.
Art. 12 Request the Beneficiary to provide
6.1.a.(i) information regarding its usual
accounting practices as regards
recording of costs incurred in currency
other than its local currency.
If the accounting documents justifying
the costs for subcontracting are in
foreign currency, ensure that the
Beneficiary converted the costs when
recording the latter in its statutory
accounting books in conformity with its
usual accounting practices.
Art. 13 Only if the Beneficiary does not have a
6.1.a.(i) developed IT accounting system
including project accounting that
prevent double charging of costs and
incomes to different projects, then:

a) Confirm that during a period of 6

months after recording the accounting
documents in the Beneficiary's statutory
books no altering event has been
recorded (credit note, invoice
cancellation, etc.). To that end inspect
the general accounting of the
Beneficiary as well as the suppliers'
ledgers.

b) Confirm for each sampled item that

the costs for subcontracting have not
been re-invoiced by the Beneficiary to
another legal entity, including affiliated
companies as well as independent third
parties. To confirm the latter inspect the
general accounting of the Beneficiary
up to 6 months after the date of
recording the initial justifying document.

42
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. 14 Confirm that the costs were paid by the
6.1.a.(i) Beneficiary. To that end inspect bank
statements and cash registers. In case
of other means like netting off, cash
pooling, etc. check the general ledger
and accounting system of the
Beneficiary to confirm such other form
of payment.
Art.6.5. Costs must not include deductible VAT. 15 Verify that the costs charged do not
(a)-(ix) include VAT if VAT is deductible for the
Beneficiary according to the national tax
law. To that end inspect the national tax
law, review declarations delivered by
the national tax authorities, review the
accounting system of the Beneficiary,
etc. Only beneficiaries that cannot
deduct VAT according to the national
tax law can charge VAT as a cost on the
action.
Deductible VAT which is not identifiable
is to be considered as an ineligible cost.

Non-identifiable VAT (in foreign

invoices) — In exceptional cases where
the beneficiary cannot identify the VAT
charged by the supplier (e.g. small non-
EU invoices), the full purchase price can
be recorded in the accounts if it is not
possible to deduct the VAT. That VAT
would therefore be eligible.
Art. Costs declared do not contain ineligible 16 Confirm that the declared costs for ERA-
6.5.(a) elements. subcontracting do not contain any of NET
The eligibility of duties depends on the following ineligible elements: Cof.
eligibility of the cost item to which they (i) costs related to return on capital;
are linked (i.e. in whose price they are (ii) debt and debt service charges;
included). If the item is eligible, the duty (iii) provisions for future losses or debts;
is also eligible. (iv) interest owed;
Costs to allow for the participation of (v) doubtful debts;
disabled people (e.g. costs for sign (vi) currency exchange losses;
language interpreters required for (vii) bank costs charged by the
dissemination events organised under Beneficiary’s bank for transfers from
the action) — May be eligible if they the EC;
fulfil the general and specific eligibility
conditions listed under Articles 6.1 and
6.2. The beneficiaries must keep records
(see Article 18) to prove in case of an
audit, check or review the actual costs
incurred and that they were necessary
for the implementation of the action.

43
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. Costs must be incurred during the 17 Verify by reviewing the invoices,
6.1.a.(ii project period defined in Art.3 of the delivery notes, etc. that the day/period
) Grant Agreement(s) or any subsequent of the delivery of the subcontracted
amendments with exception of costs service lies within the project period as
relating to submission of the periodic specified in Art.3 of the Grant
report for the last reporting period and Agreement(s) or any subsequent
the final report. amendments.

The costs which are incurred outside the

project period and are not related to the
submission of the periodic report for the
last reporting period or the final report
should be reported as adjustment to the
costs declared pending confirmation of
the following procedures.
Art. 18 For costs incurred after the end of the
6.1.a.(ii action, inquire if the latter relate to the
) periodic report of the last reporting
period or the final report. To that end
review the available accounting
documents and reports, determine the
nature of the cost and obtain relevant
information from the Beneficiary.
Art. 19 Confirm that the accounting documents
6.1.a.(ii justifying the costs for subcontracting
) are recorded in the Beneficiary's
statutory accounting books during the
reporting period in which the costs are
declared.
OR
Confirm that a debt corresponding to
the final known amount for the cost
item has been recorded in the
Beneficiary's statutory books during the
reporting period in which the costs are
declared.

44
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. Costs must not include any costs 20 Identify any costs incurred during
6.5.(a)- incurred during suspension of the suspension of the implementation of
(x) implementation of the action (Art.49). the action. To that end inspect
amendments of the Grant Agreement(s),
correspondence between the EC/
AGENCY / JU and the Beneficiary and
information at disposal of the
Beneficiary.
Gather information regarding the
following:
- are the costs incurred during the
suspension of the action clearly
identifiable (does the subcontracting
foresee partial delivery of results, are
there periodical invoices, separate
charges for separate elements, etc.);
- was the suspension notified by the
beneficiary to the subcontractor (what
were the measures taken);
- was the amendment of the grant
lifting the suspension changing the
subcontracting in terms of tasks to be
executed, amount involved, etc.
Art. Costs must be identifiable and 21 Confirm that the original primary
6.1.(a)- verifiable, in particular recorded in the accounting documents included in the
(v) Beneficiary’s accounts in accordance underlying documentation justifying the
with the accounting standards costs for subcontracting (invoices, debit
applicable in the country where the notes, credit notes, etc.) are in
Beneficiary is established and with the compliance with the national accounting
Beneficiary’s usual cost accounting standards (e.g. bear all required
practices. requisites - date, document number,
amount, currency, etc.).
Art. 22 Verify if conforming to the national
6.1.a.(ii accounting law the Beneficiary has the
) obligation to have its annual statutory
accounts certified by an independent
auditor. If yes, request the statutory
auditor's report for the years covering
the duration of the audited period or if
the latter is not yet available - for the
last 3 years for which a report is
available. Verify if the auditor's reports
are qualified for reasons affecting the
audited cost category.

If the auditor's report on the

Beneficiary's statutory annual accounts
is not qualified for the cost category
under audit it is deemed that the costs
are recorded in accordance with the
accounting standards applicable in the
country where the Beneficiary is
established.

45
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. The Beneficiaries must keep the original 23 If the Beneficiary has presented digital
18.1. documents. Digital and digitalised or digitalised accounting documents
documents are considered originals if confirm that they are authorised by the
they are authorised by the applicable applicable national law.
national law.

Art. Costs must not include costs declared 24 Verify if the original underlying
6.5.(b) under another EU or Euratom grant documents bear exclusive reference to
(including grants awarded by a Member the EU action under audit (number and
State and financed by the EU or acronym, specific code determined by
Euratom budget and grants awarded by the Beneficiary, etc.) or are stamped
bodies other than the with the reference to the EU action
[Commission][Agency] for the purpose under audit.
of implementing the EU or Euratom
budget); in particular, indirect costs if If the original underlying documents
the Beneficiary is already receiving an bear reference of another EU or
operating grant financed by the EU or Euratom grant (including grants
Euratom budget in the same period. awarded by a Member State and
financed by the EU or Euratom budget
and grants awarded by bodies other
than the [Commission][Agency] for the
purpose of implementing the EU or
Euratom budget) the costs should be
rejected. .
Art. 25 Review the cost accounting, the
6.5.(b) controlling system and the relevant
procedures of the Beneficiary. Identify
the existence of specific project
accounting (e.g. existence of specific
cost centres, internal orders, sub-
ledgers, etc. per project). Perform a
walk-trough review of the procedures to
ensure that when recorded the costs
can be allocated exclusively to one
project.

Art. 6.5 26 Obtain information from the Beneficiary

(b) whether the audited entity participates
in other EU programmes, in particular
Structural Funds, Social Fund, etc. and
obtain a list of the other EU
actions/projects running during the
audited period.

Only if the Beneficiary does not have a

developed IT accounting system
including project accounting that
prevent double charging of costs and
incomes to different projects, obtain for
5 other projects/ actions the list of
items declared for the other EU
actions/projects. Verify that none of
sampled items is included in the cost
claims of the 5 other projects/actions.

46
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art.6.1 Costs must be: 27 Confirm that the Beneficiary signed a
- incurred in connection with the action representation letter stating that the
as described in Annex 1; costs charged to the action are:
- necessary for the implementation of - incurred in connection with the action
the action; as described in Annex 1;
- reasonable and justified; - necessary for the implementation of
- comply with the principle of sound the action;
financial management, in particular - reasonable and justified;
regarding economy and efficiency; - comply with the principle of sound
- costs are incurred in absence of financial management, in particular
conflict of interest; regarding economy and efficiency;
- not declared under another EU or - costs are incurred in absence of
Euratom grant; conflict of interest;
-not incurred during suspension of the - not declared under another EU or
implementation of the action Euratom grant;
(according to Art. 49) -not incurred during suspension of the
implementation of the action (according
to Art. 49)
Art. Costs for subcontracting were incurred 28 Verify the existence of the Beneficiary's
35.1 in absence of conflict of interest. policy on Conflict of Interests. Enquire
whether the Beneficiary's internal
written procedures foresee measures
for avoidance of conflict of interest by
defining specific criteria that need to be
met.
Art. The Beneficiary ensured that the 29 Review contracts and agreements
13.1.1 Agency, the Commission, the European between the Beneficiary and its
Court of Auditors (ECA) and the subcontractors for clauses ensuring to
European Anti-Fraud Office (OLAF) can the European Commission / Agency,
exercise their rights under Articles 22 European Court of Auditors (ECA) and
and 23 also towards their the European Anti-Fraud Office (OLAF)
subcontractors. their rights under Articles 22 and 23 of
the Grant Agreement(s).
Art. Obligations that must be extended to 30 Review contracts and agreements
13.1.2 subcontractors: between the Beneficiary and its
- Avoiding conflicts of interest (see subcontractors for clauses foreseeing
Article 35) that obligations conforming to Art. 35,
- Maintaining confidentiality (see Article 36, 38 and 46 of the H2020 GA also
36) apply to the subcontracting entities.
- Promoting the action and give visibility
to the EU funding (see Article 38)
- Liability for damages (see Article 46).
It is the beneficiaries’ responsibility to
ensure that these obligations are
accepted by the subcontractors.

The beneficiaries must make special

arrangements regarding results
produced by the subcontractors (in
order to be able to fully comply with
their obligations under the GA; see
Article 26.3).

47
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. The subcontracted tasks as described in 31 Confirm that none of the subcontracted
13.1 the original signed subcontracting tasks are to be carried out exclusively
agreements did not include tasks to be by the action's coordinator as per
executed exclusively by the action's Art.41.2.b).
coordinator as listed in article 41.2.b) of
the H2020 GA.

Art. The specific eligibility conditions 32 Obtain and review the signed Grant SME-
13.1.1 foreseen in an option in the Grant Agreement(s). Confirm that if specific Ph2
Agreement for subcontracting above a provisions are foreseen in case the
defined threshold should be complied subcontracting costs exceed the
with. threshold defined in the GA the latter
are complied with.
Art. If classified results are subcontracted 33 Obtain and review the signed Grant
13.1.1 the explicit approval (in written) of the Agreement(s). Confirm that if the option
Commission has been given. of subcontracting of classified results is
activated in the Grant Agreement (Art.
13.1.1) there is a written explicit
agreement of the Commission.

Art. 34 Obtain the signed original

13.1.1 subcontracting agreements linked to the
sampled items.
Art. 35 Confirm that the original primary
13.1.1 accounting documents (invoices, debit
notes, credit notes, etc.) justifying the
declared costs for subcontracting are
issued by the same legal entity with
which the Beneficiary has signed
subcontracting agreements.
Art. 36 Confirm that the original primary
13.1.1 accounting documents (invoices, debit
notes, credit notes, etc.) justifying the
declared costs for subcontracting are
not issued before the signature of the
relevant subcontracting agreements.
Art. 37 Confirm that the description of the
13.1.1 subcontracted tasks as it appears on
the original primary accounting
documents is the same as the
subcontracting tasks foreseen in the
signed original subcontracting
agreements.
Art. 38 Confirm that the amount reflected in
13.1.1 each underlying document is in line with
the contractual agreement between the
Beneficiary and the subcontractor(s).
Art. 39 Confirm that the amount reflected in
13.1.1 each underlying document takes into
account any rebates, discounts and
other price reductions if the latter were
foreseen in the signed original
subcontracting agreements.

48
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. The original signed subcontracting 40 Confirm that the legal entities with
13.1 agreements were not concluded with a which subcontracting agreements are
Beneficiary in the same Grant concluded are not beneficiaries in the
Agreement. audited Grant Agreement(s).
Art. If the subcontracting was awarded on 41 If the subcontracting was awarded on SME-
13.1 the basis of an existing framework the basis of an existing framework Ph2
contract the name of the subcontracting contract confirm that the original signed
supplier was listed in Annex I subcontracting agreements are signed
Description of Work of the audited with the legal entity stated in Annex 1
Grant Agreement(s). Description of Work of the audited
Grant Agreement(s). If the Beneficiary
awarded subcontracting on the basis of
an existing framework contract, but the
name of the subcontractor is different
from the one specified in Annex 1
request the Beneficiary to provide
detailed explanations for the change of
supplier, including comparison of offers.

49
Contracting Authority
SPEC.
GA Art. Condition to be checked N. General procedure to be performed
PROC.
Art. Beneficiaries that are 42 Verify by confirming with the Beneficiary, by SME-
13.1.2 ‘contracting authorities’ within reviewing confirmations by authorities or other Ph2
the meaning of Directive legal statutory documents whether the audited
2004/18/EC24 or ‘contracting Beneficiary is a ‘contracting authority’ within
entities’ within the meaning of the meaning of Directive 2004/18/EC or a
Directive 2004/17/EC25 must ‘contracting entity’ within the meaning of
comply with the applicable Directive 2004/17/EC. If it is the case obtain
national law on public the applicable national law on public
procurement. procurement and confirm that the applicable
national law on public procurement was
correctly applied.
Art. 43 If the entity is a ‘contracting authority’ within SME-
13.1.2 the meaning of Directive 2004/18/EC or a Ph2
‘contracting entity’ within the meaning of
Directive 2004/17/EC confirm that :
- where a procurement procedure is required
by the national applicable law on public
procurement the procedure was carried out;
Art. 44 - there is a publication of a call for tenders SME-
13.1.2 when it is compulsory by the national Ph2
applicable law on public procurement;
Art. 45 - the minimum advertising time foreseen in the SME-
13.1.2 public procurement rules was respected; Ph2
Art. 46 - the minimum number of offers was obtained SME-
13.1.2 as foreseen in the public procurement rules; Ph2
Art. 47 - the minimum waiting time between awarding SME-
13.1.2 and signing the contract (or purchase order) Ph2
that is foreseen in the public procurement rules
was respected;
Art. 48 - the tendering for identical services and goods SME-
13.1.2 which occurred during all controlled periods of Ph2
the action was done in one tender (e.g. no split
was done to avoid publishing a tender);
Art. 49 - confirm that the subcontract is awarded to SME-
13.1.2 the entity ranked first in the selection process; Ph2
Art. 50 - confirm that existing framework contracts SME-
13.1.2 are not prolonged without a new selection Ph2
procedure or with substantial modification of
the conditions. The substantial modification of
the conditions is limited to increase of the price
and/or change of the scope.

50
Not Contracting Authority
GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. The beneficiaries must 51 Obtain the internal procurement procedure of the SME-
13.1.1 award the subcontracts Beneficiary. Ph2
ensuring the best value for
money or, if appropriate,
the lowest price.
Art. 52 If the internal procurement procedure of the SME-
13.1.1 Beneficiary requires tendering in order to select the Ph2
subcontracting entity carry out the following
procedures.
Obtain:
- original tender notice or letters of invitation to
tender;
- tender specifications;
- all copies of all tenders finally received, including
those of the losing bidders;
- the composition of the evaluation committee;
- the final award decision and recommendation made;
- the letter of confirmation of award, as well as
notifications of non-success to losing bidders and
subsequent responses to requests for clarification or
complaints by those losing bidders.
Art. 53 Confirm that the Beneficiary applied its written SME-
13.1.1 internal procedures for procurement in terms of Ph2
amounts' ceiling (e.g. if the procedure foresees for
awarding of bids above 10 000 EUR to collect 3 offers
the Beneficiary did collect the required number of
offers).
Art. 54 In the case of more than one controlled period sum SME-
13.1.1 the costs for subcontracting invoiced for identical Ph2
services by the same supplier. Confirm that no change
would have occurred in the selection process
compared to the Beneficiary's written internal
procedures for procurement if the subcontracting
would have been awarded in one lot (to avoid splitting
subcontracting to lots in order to drop below the
ceiling for tendering).
Art. 55 Confirm that the Beneficiary applied its written SME-
13.1.1 internal procedure for procurement in terms of Ph2
publicity of the tender (e.g. appropriate media,
sufficient deadline for reply, etc.).

Art. 56 Confirm that the tendering conditions or the minimum SME-

13.1.1 requirements for the offers were not modified after Ph2
the publication of the tender or if it was the case the
modifications have been published in the same
manner as the initial tender and notified to all bidders
which already submitted its offer and these bidders
were given the possibility to re-submit the offer.
Art. 57 Confirm that the evaluation of the offers was carried SME-
13.1.1 out based on the criteria published in the tender (e.g. Ph2
no new criteria and conditions are added at evaluation
stage).
Art. 58 Confirm that price is one of the criteria based on SME-
13.1.1 which the offers' evaluations was carried out. Ph2

51
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. 59 Confirm that the entity offering lowest price has been SME-
13.1.1 awarded the highest score for the price criteria. Ph2
Art. 60 Confirm that if the Beneficiary did not award the SME-
13.1.1 subcontracting to the entity offering the lowest price Ph2
the award decision contains a justification about the
criteria which explain the choice of another bidder
than the one offering lowest price.
Art. 61 Confirm that the subcontract is awarded to the entity SME-
13.1.1 ranked first in the selection process. Ph2
Art. 62 Confirm that the applied procurement procedure does SME-
13.1.1 not discriminate purchases for EU-funded and non-EU Ph2
funded activities of the Beneficiary.

In cases in which the Beneficiary has a procurement

procedure which is correctly applied (e.g. the walk
through could be completed without findings) when
selecting the supplier the costs are deemed to be
reasonable, justified, not reckless and not excessive, to
comply with the principle of sound financial
management, in particular regarding economy and
efficiency and with the principle of "best value for
money". In cases in which the Beneficiary has a
procurement procedure but the latter has not been
applied correctly (e.g. the walk through results in non-
compliance of the selection process with the
procedure) or a discrimination between purchase for
EU-funded and non-EU funded activities has been
observed the relevant costs should be rejected, unless
the Beneficiary can provide a persuasive justification.
Art. 63 In cases in which the Beneficiary has no procurement SME-
13.1.1 procedure request the Beneficiary to describe its Ph2
approach when selecting the subcontractor(s). Request
from the Beneficiary documents and justifications
supporting the approach taken.

If the Beneficiary has no procurement procedure in

place but has taken actions in order to ensure
selection based on the principle of best value for
money or lowest price the auditors verify the approach
taken and vouch the received information to the latter.
In cases in which discrimination between purchase for
EU-funded and non-EU funded activities has been
observed the relevant costs should be rejected, unless
the Beneficiary can provide a persuasive justification.
If the Beneficiary has a defined approach, was able to
support it with documents and justifications and there
is no discrimination between purchase for EU-funded
and non-EU funded activities the costs can be deemed
to be eligible if the other eligibility conditions are met.
Otherwise, the auditors carry out procedure 64.
Art. 64 In cases in which the Beneficiary has no procurement SME-
13.1.1 procedure nor has it taken specific approach when Ph2
selecting the subcontractor(s) request the Beneficiary
to provide any justifications which can ensure that the
costs are compliant with the principle of best value for
money or selection on lowest price.

52
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. In case that the original 65 Confirm that if the subcontracting agreements are SME-
13.1 signed subcontracting concluded with an affiliated entity that a framework Ph2
agreements were concluded contract exists or the affiliate is the Beneficiary's
with an affiliate company usual provider. To that end inspect the suppliers'
the following conditions ledger of the Beneficiary, invoices from the affiliate
were met: 1) a framework established prior to the action start, etc.
contract with the
Beneficiary must exist OR 2)
the affiliate is the
Beneficiary's usual provider,
AND 3) the subcontracting
is priced at market
conditions.
Art. 66 Request the Beneficiary to obtain an offer from an SME-
13.1 alternative supplier for the same product or service. If Ph2
the foregoing is not possible, request the beneficiary
to enquire on open sources in order to identify
alternative suppliers of the same product or service.

Final General Control

GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art.13 FINAL GENERAL CONTROL 67 In cases in which the procedures listed above have
been carried out successfully but the auditor, during
the execution of these procedures, came across facts
and documents which put into question the
compliance of the costs with the eligibility criteria
foreseen in the H2020 Grant Agreement this
information should be reported accompanied with
adequate supporting documents

53
D. OTHER DIRECT COSTS
General Procedures
GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. 6.3 Costs incurred by linked third 1 Verify if the costs incurred by linked third
parties are eligible if they fulfil - parties fulfil - mutatis mutandis - the general
mutatis mutandis - the general specific conditions for eligibility set out in Art.
specific conditions for eligibility set 6.1 and Art. 6.2. Perform the procedures
out in Art. 6.1 and Art. 6.2 and Art. included in this file.
14.1.1 (on linked third parties)
Art. 14 [Linked third parties] must be 2 a) Verify that the third parties, for whom costs
named in Article 14 and their were incurred and claimed, are included in the
action tasks and estimated costs GA including amendments.
must be set out in Annexes 1 and
2 already at the moment of the GA b) Verify that their participation in the action
signature (or if the linked third has not been terminated.
party is added later, through an
amendment; see Article 55). c) Enquire if the third parties (including
The beneficiaries must make personnel) may claim rights to the results (Art.
special arrangements regarding 26.3).
results produced by the linked third
parties (in order to be able to fully
comply with their obligations under
the GA; see Article 26.3)

Art. Costs must be actually incurred by 3 Obtain from the Beneficiary the list of items
6.1.a. the Beneficiary. for which other direct costs are claimed,
(i) broken down by sub-category.
Art. 4 Confirm that the total amount resulting from
6.1.a. the list of items corresponds to the amount
(i) claimed in the financial statement(s). For
beneficiaries with accounting established in
other currency than the euro first convert the
total amount resulting from the list of items to
euro by using the rate as specified in Art.20.6
of the H2020 GA.

54
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. 5 Select a sample from the list of items for each
6.1.a. sub-category as follows:
(i) 1) If the total costs in the sub-category is
below the planning materiality level (5% of
total costs claimed) the item with the highest
value in the population should be taken;

2) If the total costs in the sub-category is

above the planning materiality level (5% of
total costs claimed) then

2.a) if the population is less or equal to 5

items, all items should be tested; or

2.b) If the population is more than 15 items

select for testing a maximum of 15 items.
Select for testing all the items with a value
higher or equal to 10% of the costs declared
for the costs subcategory. Add randomly
selected items until 50% coverage of the costs
in the sub-category is achieved or the total
maximum number of 15 items is reached.

The Definition of an item is one person travel

cost for an event/ conference for travel costs;
and one line in the breakdown for
Consumables and Equipment.
Art. 6 If systemic or recurrent errors are identified
6.1.a. request the Beneficiary to recalculate the
(i) declared costs for the action by removing the
effect of the systemic or recurrent errors for
the whole population. Verify the accuracy and
reliability of the recalculation performed by
the Beneficiary.
Art. 7 Obtain from the Beneficiary the underlying
6.1.a. documentation (supplier invoices, debit notes,
(i) credit notes, expense claims, etc.) justifying
the costs for the randomly selected items.
Reconcile in monetary terms each item from
the sample to the specific underlying
document.
Art. 8 Ensure that the underlying documents are
6.1.a. addressed to the Beneficiary. The procedure is
(i) valid only in cases in which the underlying
documents are issued by external to the
Beneficiary entity. The procedure is not to be
carried out in cases in which the costs are
based on internal transactions (e.g. internal
invoices, depreciation, etc.).
Art. 9 Confirm that the accounting documents
6.1.a. justifying the sampled items (invoices, debit
(i) notes, credit notes, expense claims, etc.) are
recorded in the Beneficiary's statutory
accounting books.

55
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. 10 Request the Beneficiary to provide information
6.1.a. regarding its usual accounting practices for
(i) recording of costs incurred in other currency
that its local currency. If the accounting
documents justifying the sampled items are
labelled in foreign currency confirm that the
Beneficiary converted the costs in conformity
with its usual accounting practices.
Art. 11 Only if the Beneficiary does not have a
6.1.a. developed IT accounting system including
(i) project accounting that prevent double
charging of costs and incomes to different
projects, then
a) Confirm that during a period of 6 months
after recording the accounting documents in
the Beneficiary's statutory books no altering
event has been recorded (credit note, invoice
cancellation, etc.). To that end inspect the
general accounting of the Beneficiary as well
as the assets' and suppliers' ledgers.
b) Confirm for each item that the sampled
other direct costs have not been reinvoiced by
the Beneficiary to another legal entity,
including affiliated companies as well as
independent third parties. To confirm the latter
inspect the general accounting of the
Beneficiary up to 6 months after the date of
recording the initial justifying document.
Art. 12 Confirm that the amount reflected in each
6.1.a. underlying document justifying the selected
(i) items takes into account any rebates,
discounts and other price reductions if the
latter were foreseen. To that end inspect the
general accounting of the Beneficiary,
commercial agreements, contracts, interview
accounting staff, etc.
Art. 13 Confirm that the costs linked to the sampled
6.1.a. items were paid by the Beneficiary. To that
(i) end inspect bank statements and cash
registers. In case of other means like netting
off, cash pooling, etc. check the general ledger
and accounting system of the Beneficiary to
confirm such other form of payment.

56
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art.6.5. Costs must not include deductible 14 Verify that the costs charged do not include
(a).(ix) VAT. VAT if VAT is deductible for the Beneficiary
according to the national tax law. To that end
inspect the national tax law, review
declarations delivered by the national tax
authorities, review the accounting system of
the Beneficiary, etc. Only beneficiaries that
cannot deduct VAT according to the national
tax law can charge VAT as a cost on the
action. Deductible VAT which is not identifiable
is to be considered as an ineligible cost.
Non-identifiable VAT (in foreign invoices) — In
exceptional cases where the beneficiary
cannot identify the VAT charged by the
supplier (e.g. small non-EU invoices), the full
purchase price can be recorded in the accounts
if it is not possible to deduct the VAT. That VAT
would therefore be eligible.

Art. Costs claimed do not contain 15 Confirm that the claimed other direct costs do
6.5.a) ineligible elements. not contain any of following ineligible
elements:
The eligibility of duties depends (i) costs related to return on capital;
on the eligibility of the cost item to (ii) debt and debt service charges;
which they are linked (i.e. in whose (iii) provisions for future losses or debts;
price they are included). If the item (iv) interest owed;
is eligible, the duty is also eligible. (v) doubtful debts;
(vi) currency exchange losses;
Costs to allow for the participation (vii) bank costs charged by the Beneficiary’s
of disabled people (e.g. costs for bank for transfers from the EC / AGENCY / JU;
sign language interpreters required
for dissemination events organised
under the action) — May be
eligible if they fulfil the general
and specific eligibility conditions
listed under Articles 6.1 and 6.2.
The beneficiaries must keep
records (see Article 18) to prove in
case of an audit, check or review
the actual costs incurred and that
they were necessary for the
implementation of the action.

57
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. Costs must be incurred during the 16 Verify by reviewing the invoices, delivery
6.1.a project period defined in Art.3 of notes, transport documents, stock registers
(ii) the grant agreement(s) or any etc. that the day of the delivery or the start of
subsequent amendments with use of the asset, good or service lies within
exception for costs relating to the project period as specified in Art.3 of the
submission of the periodic report grant agreement(s) or any subsequent
for the last reporting period and amendments. If travel and subsistence costs
the final report. are concerned verify that the travel or any
other event for which costs are claimed
(meals, etc.) occurred during the period.

The costs which are incurred outside the

project period and are not related to the
submission of the periodic report for the last
reporting period or the final report should be
reported as adjustment to the costs claimed
pending confirmation of the following
procedures.
Art. 17 For costs incurred after the end of the action,
6.1.a inquire if the latter relate to the periodic report
(ii) of the last reporting period or the final report.
To that end review the available accounting
documents and reports, determine the nature
of the cost and obtain relevant information
from the Beneficiary.
Art. 18 Confirm that the accounting documents
6.1.a justifying the other direct costs are recorded in
(ii) the Beneficiary's statutory accounting books
during the reporting period in which the costs
are claimed.
OR
Confirm that a debt corresponding to the final
known amount for the cost item has been
recorded in the Beneficiary's statutory books
during the reporting period in which the costs
are claimed.
Art. 19 If the controlled period is the first reporting
6.1.a period and if the travel occurred before the
(ii) action's start date confirm that the travel
relates exclusively to the first "leg" of the kick-
off meeting. Confirm that the kick-off meeting
itself took place during the action duration.
Art. 6.5 Costs must not include any costs 20 Identify any costs incurred during suspension
(a).(x) incurred during suspension of the of the implementation of the action. To that
implementation of the action end inspect amendments of the grant
(Art.49). agreement(s), correspondence between the EC
/ AGENCY / JU and the Beneficiary and
information at disposal of the Beneficiary.

58
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. 6.1 Costs must be identifiable and 21 Confirm that the original accounting
(a) (v) verifiable, in particular recorded in documents included in the underlying
the Beneficiary’s accounts in documentation justifying the costs (limited to
accordance with the accounting invoices, debit notes, credit notes) are in
standards applicable in the country compliance with the national accounting
where the Beneficiary is standards (e.g. bear all required requisites -
established and with the date, document number, amount, currency,
Beneficiary’s usual cost accounting etc.).
practices.
Art. 6.1 22 Verify if conforming to the national accounting
(a) (v) law the Beneficiary has the obligation to have
its annual statutory accounts certified by an
independent auditor. If yes, request the
statutory auditor's report for the years
covering the duration of the audited period or
if the latter is not yet available - for the last 3
years for which a report is available. Verify if
the auditor's report is qualified for reasons
affecting the audited cost category.

If the auditor's report on the Beneficiary's

statutory annual accounts is not qualified for
the cost category under audit the costs can be
deemed to have been recorded in accordance
with the accounting standards applicable in
the country where the Beneficiary is
established.
Art.18. The beneficiaries must keep the 23 If the Beneficiary has presented digital or
1. original documents. Digital and digitalised accounting documents confirm that
digitalised documents are they are authorised by the applicable national
considered originals if they are law.
authorised by the applicable
national law.
Art. 6.1 Costs must comply with the 24 Verify by
(a) (vi) applicable national law on taxes, 1) assessing the applicable national law on
labour and social security. taxes, labour and social security;
2) inquiring with the Beneficiary;
3) checking reports of the financial authorities
and
4) checking reports of internal/external
auditors that the costs were dealt with
according to applicable national law on taxes,
labour and social security.

59
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. 6.5 Costs must not include costs 25 Verify if the original underlying documents
(b) declared under another EU or bear exclusive reference to the EU action
Euratom grant (including grants under audit (number and acronym, specific
awarded by a Member State and code determined by the Beneficiary, etc.) or
financed by the EU or Euratom are stamped with the reference to the EU
budget and grants awarded by action under audit.
bodies other than the
[Commission][Agency] for the If the original underlying documents bear
purpose of implementing the EU or reference of another EU or Euratom grant
Euratom budget); in particular, (including grants awarded by a Member State
indirect costs if the Beneficiary is and financed by the EU or Euratom budget and
already receiving an operating grants awarded by bodies other than the
grant financed by the EU or [Commission][Agency] for the purpose of
Euratom budget in the same implementing the EU or Euratom budget) the
period, unless it can demonstrate costs should be rejected.
that the operating grant does not
cover any costs of the action .
Art. 6.5 26 Review the cost accounting, controlling system
(b) and relevant procedures of the Beneficiary.
Identify the existence of specific project
accounting (e.g. existence of specific cost
centres, internal orders, sub-ledgers, etc. per
project). Perform a walk-trough review of the
procedures to ensure that when recorded the
costs can be allocated exclusively to one
project.

Art. 6.5 27 Obtain information from the Beneficiary

(b) whether the audited entity participates in
other EU programmes, in particular Structural
Funds, Social Fund, etc. and obtain a list of the
other EU actions/projects running during the
audited period.

Only if the Beneficiary does not have a

developed IT accounting system including
project accounting that prevent double
charging of costs and incomes to different
projects, then obtain for 5 other
projects/actions the list of items declared
under other direct costs. Verify that none of
sampled items is included in the cost claims of
the 5 other projects/actions.
Art. 6.5 28 Enquire whether the Beneficiary receives
(b) assets, goods or services from the State for
free specifically in relation to the audited
action and verify that a procedure exists in
order to avoid that such items are included in
the H2020 cost claims.
If no procedure exists, check 5 transactions
concerning assets, goods and services made
available by the State for free for that specific
project, and verify that they do not appear in
the project cost accounting of the EU action
under audit.

60
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art.6.1 Costs must be: 29 Confirm that the Beneficiary signed a
- incurred in connection with the representation letter stating that the costs
action as described in Annex 1 of charged to the action are:
the grant agreement; - incurred in connection with the action as
- necessary for the implementation described in Annex 1 of the grant agreement;
of the action; - necessary for the implementation of the
- reasonable and justified; action;
- comply with the principle of - reasonable and justified;
sound financial management, in - comply with the principle of sound financial
particular regarding economy and management, in particular regarding economy
efficiency; and efficiency;
- costs are incurred in absence of - incurred in absence of conflict of interest;
conflict of interest; - not declared under another EU or Euratom
- not declared under another EU or grant;
Euratom grant; -_not incurred during suspension of the
- not incurred during suspension of implementation of the action (according to Art.
the implementation of the action 49)
(according to Art. 49)
Art. Beneficiaries that are ‘contracting 30 Verify by confirming with the Beneficiary, by SME-
10.1.2 authorities’ within the meaning of reviewing confirmations by national authorities Ph2
Directive 2004/18/EC24 or or other legal statutory documents whether
‘contracting entities’ within the the audited Beneficiary is a ‘contracting
meaning of Directive 2004/17/EC25 authority’ within the meaning of Directive
must comply with the applicable 2004/18/EC or a ‘contracting entity’ within the
national law on public meaning of Directive 2004/17/EC. If it is the
procurement. case obtain the applicable national law on
public procurement and confirm that the
applicable national law on public procurement
was correctly applied.

61
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. 31 If the entity is a ‘contracting authority’ within SME-
10.1.2 the meaning of Directive 2004/18/EC or a Ph2
‘contracting entity’ within the meaning of
Directive 2004/17/EC confirm that :
- where a procurement procedure is required
by the national applicable law on public
procurement the procedure was carried out;
- there is a publication of a call for tenders
when it is compulsory by the national
applicable law on public procurement;
- the minimum advertising time foreseen in
the public procurement rules was respected;
- the minimum number of offers was obtained
as foreseen in the public procurement rules;
- the minimum waiting time between awarding
and signing the contract (or purchase order)
that is foreseen in the public procurement
rules was respected;
- the tendering for identical services and
goods which occurred during all controlled
periods of the action was done in one tender
(e.g. no artificial split was done to avoid
publishing a tender);
- confirm that existing framework contracts
are not prolonged without a new selection
procedure and/or with substantial modification
of the conditions. The substantial modification
of the conditions is limited to increase of the
price and/or change of the scope;
Art. The beneficiaries must take all 32 Enquire whether the Beneficiary's internal
35.1 measures to prevent any situation written procedures foresee measures for
where the impartial and objective avoidance of conflict of interest by defining
implementation of the action is specific criteria that need to be met.
compromised for reasons involving
economic interest, political or
national affinity, family or
emotional ties or any other shared
interest (‘conflict of interests’).
10.1.1 The beneficiaries must ensure that 33 Review contracts and agreements between the
[the Agency,] the Commission, the Beneficiary and its suppliers of other direct
European Court of Auditors (ECA) costs for clauses ensuring to the European
and the European Anti-Fraud Commission / Agency, European Court of
Office (OLAF) can exercise their Auditors (ECA) and the European Anti-Fraud
rights under Articles 22 and 23 Office (OLAF) their rights under Articles 22 and
also towards their contractors. 23 of the grant agreement(s).

62
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. Promoting of the action – 34 When verifying the actual existence of the ERC
38.1.2 visibility of EU funding sampled assets by physical inspection, verify
e Unless the [Commission][Agency] whether the EU emblem is displayed and
requests or agrees otherwise or whether the text " This
unless it is impossible, any [infrastructure][equipment][insert type of
communication activity related to result] is part of a project that has received
the action (including in electronic funding from the [European Union’s Horizon
form, via social media, etc.) and 2020 research and innovation
any infrastructure, equipment and programme][Euratom research and training
major results funded by the grant programme 2014-2018] under grant
must: agreement No [number]" is included.
(a) display the EU emblem and
(b) include the following text: When the EU emblem is displayed together
For communication activities: “This with another emblem or logo, assess whether
project has received funding from the EU logo has appropriate prominence.
the [European Union’s Horizon
2020 research and innovation
programme][Euratom research and
training programme 2014-2018]
under grant agreement No
[number]”.
For infrastructure, equipment and
major results: “This
[infrastructure][equipment][insert
type of result] is part of a project
that has received funding from the
[European Union’s Horizon 2020
research and innovation
programme][Euratom research and
training programme 2014-2018]
under grant agreement No
[number]”.
When displayed together with
another logo, the EU emblem must
have appropriate prominence.
Art.10. Purchases between 35 For each sampled good or service verify that
1 beneficiaries are in principle not the good or service is not invoiced by another
accepted. If a beneficiary needs beneficiary of the Grant Agreement.
supplies from another beneficiary,
it is the latter beneficiary that If any good or service is invoiced by another
should charge them to the action. beneficiary of the Grant agreement, verify
(Otherwise there is the risk that that: the other Beneficiary is a usual supplier
the grant is used to charge and the good is a generic consumable required
commercial profit margins). for the action.
Purchases between beneficiaries
will only be accepted in exceptional
and properly justified cases (e.g.
beneficiary A is a usual supplier of
beneficiary B for a generic
consumable beneficiary B needs
for the action).

63
D.1. Travel costs and related subsistence allowances
Spec.
GA Art. Condition to be checked N. General procedure to be performed
Proc.
Art. Costs must be actually incurred by 36 a) If a sampled item is an expense claim
6.1.a. (i) the Beneficiary. confirm that the total costs of the expense
claim reconcile with the sum of the amounts
stemming from the justifying documents
(tickets, bills, receipts, etc.).
b) If the costs are incurred in other than the
local currency of the Beneficiary convert the
latter to the currency of the Beneficiary
conforming to its usual accounting practices.
Art. Costs must be incurred in 37 Obtain from the Beneficiary its written travel
6.1.a) (v) accordance with the Beneficiary's policy and written internal procedures in the
usual cost accounting practices matter.
Art. Combination with personal travels 38 Confirm that the claimed travel and
6.2.D.1 or travels for other purposes —The subsistence costs are compliant with the
costs of a combined travel can be Beneficiary's written internal policy and
charged to the action — but ONLY procedures (no upgrade of the usual travel
up to the cost that would have policy took place for the purpose of claiming
been incurred if the travel would costs on the audited action).
have been made exclusively for
the action AND if: For cases of combined travel with personal
- it is the usual practice of the travels or travels for other purposes, verify
beneficiary to pay for such travels that it is the usual practice of the beneficiary
(e.g. travels combining professional to pay for such travels.
and personal reasons)
- it has been an actual cost for the For an expense claim related to the costs of a
beneficiary. combined travel with personal travels or
travels for other purposes, confirm that the
cost charged to the action are limited to the
costs that would have been incurred if the
travel would have been made exclusively for
the action.
Obtain from the Beneficiary justifying
documents for the actual cost of the travel as
well as evidence of the costs of the flight that
the person would have taken if it would have
returned directly after the end of the work for
the action

Art. 39 Confirm that if per diems/fixed fees were

6.2.D.1 used for claiming travel costs and related
subsistence allowances the amounts used to
charge costs on the action reconcile with the
ones foreseen in the Beneficiary's written
travel policy and internal procedures.
Art. 40 In case the Beneficiary has not a written
6.2.D.1 travel policy and/or written internal
procedures confirm that the Beneficiary
applied identical approach for all travel
arrangements claimed on the action during
the controlled period - same class for flights
and train journeys, same classification of
hotels, same per diems applied (if this option
is used) for the same category of staff
involved in the project.

64
 Spec.
GA Art. Condition to be checked N. General procedure to be performed
Proc.
Art. Travel and subsistence costs must 41 Confirm that the travel and subsistence costs
6.1.a) be necessary for the were incurred by individuals effectively
(iv) implementation of the action. working for the action. To that end compare
the list of individuals who incurred travel and
subsistence costs to
1) the individuals for which time records,
declarations on the honour or alternative
evidence providing equivalent level of
assurance for work on the action was kept by
the Beneficiary even if the corresponding
personnel costs were not claimed in the
period's financial statements;
2) the list of external experts involved in the
action;
3)_the list of selection panels' members and
approved members of user groups in cases in
which the Beneficiary declares trans-national
access to research infrastructures based on
actual costs.
Art. 42 For each sampled item for travel cost, request
6.1.a) the Beneficiary to provide a brief description,
(iv) proof of connection to the action and proof
for necessity for the action's implementation.
Evidence of connection to the action may be
retrieved in the underlying documents
(mission orders, relevant internal documents,
etc.).
Art. 43 Reconcile the dates of travel with the time
6.1.a) records of the individuals who carried out the
(iv) travel. External experts, selection panel
members and user group members are
excluded from this procedure.
Art. 44 Confirm that the event for which travel and
6.1.a) subsistence costs were claimed effectively
(iv) took place. To that end obtain minutes of
meetings, attendance lists, facilities
reservations, etc. (non-exhaustive list of
examples).
Art. 45 Confirm that the event for which travel and
6.1.a) subsistence costs were claimed was
(iv) exclusively related to the audited action (e.g.
no costs were incurred in respect to another
Community action or for other purpose).
Art. 46 Confirm that the travel arrangements for
6.1.a) which travel and subsistence costs are limited
(iv) to the duration of the event (e.g. no extra
hotel stays have been charged to the action's
financial statement). Confirm that no costs
for an accompanying person are included.
Art. 47 Review Annex I Description of Work of the
6.1.a) audited grant agreement and the periodic
(iv) reports for information about events to be
carried out in connection of the action's
implementation.

65
 Spec.
GA Art. Condition to be checked N. General procedure to be performed
Proc.
Art. The costs must be compliant with 48 Confirm that the travel and subsistence costs
6.1.a) the principle of sound financial do not include entertainment or hospitality
(vii) management (economy and expenses (including gifts, special meals and
efficiency). The costs must be dinners) except for the ones for which prior
reasonable and not reckless. acceptance was provided by the Commission
or the Agency.
Art. 49 Confirm that the travel and subsistence costs
6.1.a) do not include tips.
(vii)
Art. 50 Confirm that the travel and subsistence costs
6.1.a) do not include travel agencies' fees if the use
(vii) of travel agency is not explicitly defined in the
internal procedures of the entity.
Art. 51 Confirm that the travel and subsistence costs
6.1.a) do not include any private costs (TV, laundry,
(vii) minibar, etc.)
Art. 52 In cases in which the Beneficiary has no
6.1.a) internal procedure defining the thresholds for
(vii) hotel and daily allowances identify: 1) Hotel
allowances above 150 EUR/night
2) Daily allowances above 120 EUR/day.

Obtain information from the Beneficiary

justifying the choice of the hotel / the award
of the daily allowance.

66
D.2. Depreciation costs of equipment, infrastructure and other assets
GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. Costs charged for equipment must 53 Verify the actual existence of the assets by ERC
6.1.a be identifiable and verifiable. physical inspection. The physical inspection
(v) for intangible assets may take form of
logging on, demonstration, interviews with
staff, etc.
If the asset is located in a different location
than the one where the audit field work takes
place obtain written confirmation from the
technical personnel responsible for the
safeguard and the maintenance of the asset
that the asset exists. If assets do not exist
anymore (sold, given for free, destroyed,
disposed, etc.) inspect accounting and other
documentation to define the date on which
the asset is written-off from the asset
register.
Art. 54 Verify that the assets inspected are the
6.1.a assets purchased (e.g. by matching the serial
(v) number on the asset with the one mentioned
on the invoice/delivery note).
Art. 1) Costs must be incurred in 55 For each sampled asset verify if the asset is
6.1.a connection with the action as referenced in Annex 1 to the grant
(iv) & described in Annex 1 of the grant agreement(s) and/or the technical and
(vii), agreement, necessary for the scientific reports of the action.
Art.10. implementation of the action,
1.1, reasonable and justified, comply
Art. 35 with the principle of sound
financial management, in
particular regarding economy and
efficiency. 2) Costs must not
include excessive or reckless
expenditure, 3) The beneficiaries
must make such purchases
ensuring the best value for money
or, if appropriate, the lowest price.
In doing so, they must avoid any
conflict of interests.

67
GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
56 Obtain from the beneficiary its internal
procurement procedure. Review the
procurement procedure and perform a walk
through to confirm that the procedure has
been correctly applied when selecting the
supplier for the sampled assets. The walk
through consists of re performing the steps
foreseen in the procurement procedure
presented by the Beneficiary. Examples of
conditions to be verified, if foreseen in the
procurement procedures, are the minimum
number of offers which need to be collected,
the applicable thresholds, the non-
discrimination between purchase for EU-
funded and non-EU funded activities, etc.

In cases in which the Beneficiary has a

procurement procedure which is correctly
applied (e.g. the walk trough could be
completed without findings) when selecting
the supplier of the sampled assets the costs
of the assets are deemed to be reasonable,
justified, not reckless and not excessive, to
comply with the principle of sound financial
management, in particular regarding
economy and efficiency and with the
principle of "best value for money".
57 In cases in which the Beneficiary has no
procurement procedure request the
Beneficiary to describe its approach when
selecting the supplier(s). Request from the
Beneficiary documents and justifications
supporting the approach taken.

If the Beneficiary has no procurement

procedure in place but has taken actions in
order to ensure selection based on the
principle of best value for money or lowest
price the auditors verify the approach taken
and vouch the received information to the
latter.

If the Beneficiary has a defined approach,

was able to support it with documents and
justifications and there is no discrimination
between purchase for EU-funded and non-EU
funded activities the costs can be deemed to
be eligible if the other eligibility conditions
are met. Otherwise, the auditors carry out
procedure 58.
58 In cases in which the Beneficiary has no
procurement procedure nor has it taken
specific approach when selecting the
supplier(s) request the Beneficiary to provide
any justifications which can ensure that the
costs are compliant with the principle of best
value for money or selection on lowest price.

68
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. 6.5 Costs charged to the action must 59 If the assets were purchased in a currency
(a)vi not include any currency exchange other than the reporting currency, compare
losses. the foreign exchange rates at the date of
asset recognition and the date of the
payment in order to verify that the costs
charged did not include any currency
exchange losses.
Art. The grant must not produce a 60 a) If assets were sold, review the
5.3.3 profit. transactions to ensure that the proceedings
of the sale have been properly declared as
receipts.
b) If project specific in-kind contributions
have been received by the Beneficiary verify
that the respective receipts have been
declared.
Art.11 61 For assets contributed in-kind:
a) Verify that the contributing third parties
and their contributions are either set out in
Annex 1 or approved in writing by the
Commission.
If the in-kind contributions are NOT used on
the beneficiary’s premises, their estimated
costs must be also set out in Annex 2
(additional information column).
b) Check the underlying agreements and
confirm that the amounts do not include
estimations.
c) Verify that the costs charged, to the action
do not exceed the costs incurred by the
contributing third party and that no profit
was made. Request the beneficiary to provide
copies of the underlying documents obtained
from the third party. Consider obtaining
representation letters from the third parties.
Art. The calculation of depreciation is 62 Verify if the usual accounting practices of the
6.2. done correctly and in compliance Beneficiary include a depreciation policy and
D.2 with the applicable standards methods. Verify if these are compliant with
(International Accounting the applicable rules in the Beneficiary’s
Standards and Beneficiary's usual country and in line with the International
accounting practices). Accounting Standards.

69
GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. Low-value assets — The full cost 63 Verify for the costs of the assets included in
6.2. of a low value asset may be the sample that the following three
D.2 eligible in the year when it is cumulative criteria are met:
purchased if:
- the full cost is recorded in the 1) the full cost is recorded in the accounts of
accounts of the entity as the entity as expenditure of that year (i.e.
expenditure of that year (i.e. NOT NOT recorded as an asset subject to
recorded as an asset subject to depreciation)
depreciation) and
and 2) the cost of the asset is below the low-
- the cost of the asset is below the value ceiling as defined under national law
low-value ceiling as defined under (e.g. national tax legislation) or other
national law (e.g. national tax objective reference compatible with the
legislation) or other objective materiality principle
reference compatible with the and
materiality principle 3) the item is used exclusively for the action
and in the year of purchase. If the item is not
- the item is used exclusively for used exclusively for the action in the year of
the action in the year of purchase. purchase, only the portion used on the action
If the item is not used exclusively may be charged.
for the action in the year of
purchase, only the portion used on
the action may be charged.

64 Verify that the assets are correctly

depreciated in accordance with the applicable
rules in the Beneficiary’s country and in line
with the International Accounting Standards,
by recalculating the depreciation charged for
items included in the sample.
Cash-based accounting — As a 65 If the Beneficiary is under cash accounting
general rule, beneficiaries cannot basis, ensure in particular that depreciation is
charge the total purchase price of calculated according to International
equipment to the action, unless the Accounting Standards, and not following the
GA explicitly foresees that option. cash basis approach.
The beneficiaries may therefore
normally only charge the annual
depreciation costs that
corresponds to the part of the
equipment’s use for the action.
This depreciation must be
calculated in accordance with
international accounting standards
(i.e. notably spread over the
equipment’s useful life).

Art. The only portion of the costs that 66 Verify that only depreciation accumulated
6.2. will be taken into account is that during the period of the action is charged to
D.2 which corresponds to the duration the cost statement.
of the action and rate of actual
use for the purposes of the action

70
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Article If the beneficiary does not use the 67 For assets that are charged partially to the
6.2.D.2 equipment exclusively for the action, inquire the Beneficiary how the
action, only the portion used on the amount of use of these assets on the action
action may be charged. The was established. Ask the Beneficiary to
amount of use must be auditable. provide records, calculations and
documentation (e.g. logbooks, laboratory
registers, diaries, etc.) demonstrating the
amount of use of these assets on the action.
Reconcile the proportion of depreciation
charged on the action with the amount of
use demonstrated.
Art. The costs of renting or leasing 68 For assets which are rented or leased,
6.2. equipment, infrastructure or other request the Beneficiary to demonstrate that
D.2 assets (including related duties, the costs charged to the action do not exceed
taxes and charges such as non- by more than 25% the depreciation costs of:
deductible value added tax (VAT) - either a similar asset as it was priced at the
paid by the beneficiary) do not time of the start of the rent of the lease;
exceed the depreciation costs of - or the same asset as it was priced within a
similar equipment, infrastructure period of 6 months before and 6 months
or assets and do not include any after the start of the rent or the lease;
financing fees.
Art. 69 For assets which are rented or leased verify
6.2. that the costs charged do not include any
D.2 financing fees.
Art. The costs of equipment, 70 For assets contributed in-kind (against
6.2. infrastructure or other assets payment or for free), request the Beneficiary
D.2 contributed in-kind against to demonstrate that the costs charged to the
payment a) do not exceed the action do not exceed by more than 25% the
depreciation costs of similar depreciation costs of:
equipment, infrastructure or - either a similar asset as it was priced at the
assets; b) do not include any time of the contribution in kind;
financing fees and c) the - or the same asset as it was priced within a
conditions in Article 11.1 are met. period of 6 months before and 6 months
after the contribution in kind;
Art. 71 For assets contributed in-kind (against
6.2. payment or for free), verify that the costs
D.2 charged do not include any financing fees.
Art. 72 For assets contributed in-kind (against
6.2. payment or for free), ask the Beneficiary to
D.2 provide an explanation as to why they were
necessary to implement the action.
Art. The cost of purchasing equipment, 73 For assets that are charged at full acquisition
6.2. infrastructure or other assets (new cost and not at depreciation cost, (option 2 in
D.2 or second-hand, as recorded in the Art. 6.2. D.2) obtain from the Beneficiary
beneficiary’s accounts) may be justifications regarding the full acquisition
eligible if foreseen in the work costs' allocation on the action (nature of the
programme and if the equipment, action, context of use, etc.).
infrastructure or other assets was
purchased in accordance with
Article 10.1.1.

71
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. The Beneficiaries must not declare 74 a) Obtain information from the Beneficiary SME-
6.2. costs of renting, leasing, regarding actions in which it declares costs Ph2
D.2 purchasing depreciable equipment, for trans-national or virtual access to
infrastructure and other assets research infrastructure. Obtain the
which relates to providing trans- Beneficiary's calculation of the costs for
national or virtual access to providing trans-national or virtual access to
research infrastructure. research infrastructure for the periods under
Capital investments (i.e. costs of audit (either based on actual or unit costs).
renting, leasing, purchasing b) Verify that the costs of renting, leasing,
depreciable equipment, purchasing depreciable equipment,
infrastructure or other assets) will infrastructure and other assets declared in
NOT be reimbursed — unless the audited action are not declared as costs
provided for in the work for providing trans-national or virtual access
programme/call. to research infrastructure, unless provided
for in the work programme/call.
Art. Costs must comply with the 75 Review the signed grant agreement(s) for
10.1.1 additional eligibility criteria set in existence of a specific option in Art.10.1.1
the Grant Agreement(s) if the setting additional eligibility criteria if the
value of the purchase exceeds a value of the purchase of assets,
fixed in the Grant Agreement(s) infrastructure or equipment exceeds a
amount. defined amount. For assets purchased at a
price higher than the threshold set in article
10.1.1 of the grant agreement, verify that
the Beneficiary complied with the additional
eligibility criteria provided in that article.
Art. Costs must be declared under one 76 Enquire whether the Beneficiary has an
6.1. cost category only. approved by the EC methodology for
charging costs for Large Research
Infrastructures or claims costs of clinical
trials or energy efficiency measures based on
unit costs. Obtain the Beneficiary's
calculation of declared during the audited
period costs of clinical trials, energy
efficiency measures or LRI (on the same or
other EU-funded grants). Verify that the
assets costs charged on the audited action
are not already included in the LRI costs,
clinical studies or energy efficiency
measures' unit costs.

72
D.3 Costs for other goods and services
GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. 1) Costs must be incurred in connection 77 For each sampled good or service verify
6.1.a with the action as described in Annex 1 if the good or service is referenced in
of the grant agreement, necessary for Annex 1 to the grant agreement(s)
the implementation of the action, and/or the technical and scientific
reasonable and justified, comply with reports of the action.
the principle of sound financial
management, in particular regarding
economy and efficiency. 2) Costs must
not include excessive or reckless
expenditure, 3) The beneficiaries must
make such purchases ensuring the best
value for money or, if appropriate, the
lowest price. In doing so, they must
avoid any conflict of interests.
Art.10. 78 Obtain from the beneficiary its internal
1.1 procurement procedure. Review the
procurement procedure and perform a
walk through to confirm that the
procedure has been correctly applied
when selecting the supplier for the
sampled good or service. The walk
through consists of re performing the
steps foreseen in the procurement
procedure presented by the Beneficiary.
Examples of conditions to be verified, if
foreseen in the procurement
procedures, are the minimum number of
offers which need to be collected, the
applicable thresholds, the non-
discrimination between purchase for
EU-funded and non-EU funded
activities, etc.

In cases in which the Beneficiary has a

procurement procedure which is
correctly applied (e.g. the walk trough
could be completed without findings)
when selecting the supplier of the
sampled good or service the costs of
the good or service are deemed to be
reasonable, justified, not reckless and
not excessive, to comply with the
principle of sound financial
management, in particular regarding
economy and efficiency and with the
principle of "best value for money".

73
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art.10. 79 In cases in which the Beneficiary has no
1.1 procurement procedure request the
Beneficiary to describe its approach
when selecting the supplier(s). Request
from the Beneficiary documents and
justifications supporting the approach
taken.
If the Beneficiary has no procurement
procedure in place but has taken actions
in order to ensure selection based on
the principle of best value for money or
lowest price the auditors verify the
approach taken and vouch the received
information to the latter.
If the Beneficiary has a defined
approach, was able to support it with
documents and justifications and there
is no discrimination between purchase
for EU-funded and non-EU funded
activities the costs can be deemed to be
eligible if the other eligibility conditions
are met. Otherwise, the auditors carry
out procedure 80.
Art.10. 80 In cases in which the Beneficiary has no
1.1 procurement procedure nor has it taken
specific approach when selecting the
supplier(s) request the Beneficiary to
provide any justifications which can
ensure that the costs are compliant with
the principle of best value for money or
selection on lowest price.
Art. Cost for contributions in-kind must 81 For goods contributed in-kind (against
6.2. comply with the "arm's length" principle payment or for free), request the
D.3 Beneficiary to demonstrate that the
costs charged to the action do not
exceed by more than 25% the costs of:
- either a similar good as it was priced
at the time of the contribution in kind;
- or the same good as it was priced
within a period of 6 months before and
6 months after the contribution in kind;
Art. 82 For goods and services contributed in-
6.2. kind (against payment or for free) verify
D.3 that the costs charged do not include
any financing fees.

74
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. The beneficiaries may declare their 83 For goods and services contributed in-
6.2. costs for paying the in-kind contribution kind (against payment or for free) verify
D.3 (e.g. the invoice from the third party), that the costs charged to the action do
but only up to the costs incurred by the not exceed the costs incurred by the
third party — if the other eligibility contributing third party and that no
conditions are fulfilled (see in particular profit was made. Request the
Article 6.1 and 6.2; e.g. necessary for Beneficiary to provide copies of the
the action, recorded in the accounts of underlying documents obtained from
the beneficiary, etc.). the third party. Check the underlying
If the amount paid by the beneficiary is documents and confirm that the
lower than the cost incurred by the third amounts do not include estimations.
party, the beneficiary may in addition Consider obtaining representation
declare the difference as in-kind letters from the third parties.
contributions free of charge (see Article
12). If it decides to do so, it may have
to declare that difference also as
receipt (see Article 5.3.3).
Art. 84 For goods and services contributed in-
6.2. kind (against payment or for free),
D.3 verify that the contributing third parties
and their contributions are either set out
in Annex 1 or approved in writing by the
Commission.
If the in-kind contributions are NOT
used on the beneficiary’s premises, their
estimated costs must be also set out in
Annex 2 (additional information
column).
Art. 6.1 Costs must be identifiable and 85 Obtain from the Beneficiary its internal
(a) (v) verifiable, in particular recorded in the procedures as regards valuation
Beneficiary’s accounts in accordance methods for stocks' consumption (LIFO,
with the accounting standards FIFO, etc.). In cases in which supplies
applicable in the country where the already in stock (goods, raw materials,
Beneficiary is established and with the spare parts, components, etc.) are used
Beneficiary’s usual cost accounting for the action verify that the valuation
practices. method used to determine the costs of
these supplies is compliant with the
usual practices of the Beneficiary.
Art. 6.2 ‘Direct costs’ are costs that are directly 86 Verify that the goods and services
linked to the action implementation and directly linked to the project are
can therefore be attributed to it directly. precisely measured and charged at
costs. Verify in particular that the goods
or services are not charged to the action
through any apportionment method
(approximation, distribution keys, etc.).
To that end inspect laboratory books,
stock registers, logbooks, interview
Beneficiary's staff, etc.

75
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. 6.2 Such goods and services include, for 87 If the costs claimed in the last reporting
D.3 instance, consumables and supplies, period include the cost of a certificate
dissemination (including open access), on the financial statements verify that
protection of results, certificates on the the threshold for submitting a
financial statements (if they are certificate on the financial statements is
required by the Agreement), certificates met.
on the methodology, translations and
publications. If there are partial certificates (instead
Beneficiaries/linked third parties may of one certificate covering all costs),
submit either one certificate per verify that the total costs of the partial
reporting period or a single CFS for the certificates is similar to the cost that
whole action. would have been incurred for a single
The certificate(s) may be submitted certificate.
ONLY with the final financial report.
Certificates submitted at any other
moment will NOT be accepted (and
costs incurred for them will be
considered ineligible, because not
necessary).
Costs for partial certificates (i.e. one
certificate per reporting period) will be
accepted ONLY in the last reporting
period and ONLY if:
- a CFS is mandatory (i.e. the threshold
is reached at the end of the action) and
- the total costs of the partial
certificates is similar to the cost that
would have been incurred for a single
certificate.
Art. IPR access rights — Royalties paid for 88 Verify by checking the invoice and the
6.2 D.3 IPR access rights (and by extension any nature of the cost if it is related to IPR
lump sum payments) are normally access rights like royalties.
eligible, if all the eligibility conditions
are met (e.g. necessary for the
implementation of the action, incurred
during the action, reasonable, etc.).

Art. Protection of results — Costs related to 89 Verify by checking the invoice and the
6.2 D.3 the protection of the actions results (e.g. nature of the cost if it is related to
consulting fees, fees paid to the patent protection of results.
office for patent registration; see Article
27) are eligible if the eligibility
conditions are fulfilled. Costs related to
protection of other intellectual property
(e.g. background patents) are NOT
eligible.
Art. Plan for the exploitation and 90 Verify by checking the invoice and the
6.2 D.3 dissemination of results — Costs for nature of the cost if it is related to the
drawing up the plan for the exploitation plan for the exploitation and
and dissemination of the results are dissemination of results.
normally NOT eligible since they will
have been incurred before the start of
the action, to prepare the proposal.
Costs that occur when revising or
implementing this plan may be eligible.

76
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. Open access — Costs related to open 91 Verify by checking the invoice and the ERC
6.2 D.3 access to peer-reviewed scientific nature of the cost if is related to open
publications and research data are access. In case of fees levied for a
eligible, if the eligibility conditions are membership scheme enquire if there is
fulfilled. With explicit agreement by the explicit agreement by the Commission /
Commission / Agency, it can also include Agency.
fees levied for a membership scheme
(if this is a requirement for publishing in
open access or if membership is a pre-
condition for significantly lower article
processing charges).
16.1 ‘Access costs’ for trans-national access 92 Obtain information from the Beneficiary SME-
may be declared as unit costs, actual regarding actions in which it declares Ph2
costs or — under certain conditions — costs for trans-national or virtual access
as a combination of the two. If access to research infrastructure. Obtain ERA-
costs are declared as unit cost, they information if the beneficiary declares NET
must be declared under the budget access costs on actual or unit costs Cof.
category ‘specific cost category – basis. In cases in which the Beneficiary
access costs for providing trans- uses unit costs obtain the calculation of
national access to research the unit costs for the periods under
infrastructure’. If they are declared as audit. Verify that the costs of other
actual costs, they must be declared goods and services declared for the
under the other budget categories. audited action under section D.3 of the
The specific unit cost for access to financial statement (on actual basis) are
research infrastructure (F.2) does NOT not part of the unit costs declared for
cover virtual access (only trans-national trans-national or virtual access to
access). research infrastructure under section F.
Art. Costs must be declared under one cost 93 Enquire whether the Beneficiary has an
6.1. category only. approved by the EC methodology for
charging costs for Large Research
Infrastructures or claims costs of
clinical trials or energy efficiency
measures based on unit costs. Obtain
the Beneficiary's calculation of declared
during the audited period costs of
clinical trials, energy efficiency
measures or LRI (on the same or other
EU-funded grants). Verify that the costs
of other goods and services declared for
the audited action are not already
included in the LRI costs, clinical studies
or energy efficiency measures' unit
costs.

Art. 94 Verify by checking the accounting

6.1. records of the Beneficiary that the costs
claimed as other goods and services do
not form part of an asset to be
capitalised and depreciated.

77
D.5 Costs for internally invoiced goods and services
GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. ‘Internally invoiced goods and services’ 95 a) Review the Beneficiary's usual cost
6.2.D.5 means goods or services which are accounting practices.
provided by the beneficiary directly for
the action and which the beneficiary b) Verify that the costs of internally
values on the basis of its usual cost invoiced goods and services were
accounting practices. calculated in accordance with the
This budget category covers the costs Beneficiary's usual cost accounting
for goods and services which the practice, adjusted if necessary to
beneficiary itself produced or provided comply with the other eligibility
for the action. They include (non- conditions (e.g. removing ineligible
exhaustive list): costs).
- self-produced consumables (e.g.
electronic wafers, chemicals) c) Verify that the general eligibility
- use of specific research devices or conditions for unit costs are fulfilled
research facilities (e.g. clean room, wind (Art 6.1.(b):
tunnel, supercomputer facilities, i) they must be calculated as follows:
electronic microscope) {amounts per unit calculated by the
- specialised premises for hosting the beneficiary in accordance with its usual
research specimens used for the action cost accounting practices multiplied by
(e.g. animal house, greenhouse, the number of actual units};
aquarium) (ii) the number of actual units must
- standardised testing or research comply with the following conditions:
processes (e.g. genomic test, mass - the units must be actually used or
spectrometry analysis) produced in the period set out in Article
- hosting services for visiting 3;
researchers participating in the action - the units must be necessary for
(e.g. housing, canteen). implementing the action, and
Costs of internally invoiced goods and - the number of units must be
services directly used for the action are identifiable and verifiable, in particular
eligible, if: supported by records and
(a) they are declared on the basis documentation (see Article 18);
of a unit cost calculated in accordance
with the beneficiary’s usual cost
accounting practices; (i.e. an internal
cost per unit invoiced to other
departments of the same entity – not
prices charged in the context of
commercial sales or grants from other
fund providers)
Art. (b) the cost accounting practices 96 a) Verify that the same unit cost has
6.2.D.5 used are applied in a consistent manner, been applied in a consistent manner in
based on objective criteria, regardless at least 3 other transactions not
of the source of funding; involving the EC grants.

Beneficiaries can NOT charge the b) Verify that the commercial price is
commercial price for self-produced not used as the unit cost for internal
consumables. invoices charged to the grant.

78
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. (c) the unit cost is calculated 97 Verify that the unit cost is calculated
6.2.D.5 using the actual costs for the good or using the actual costs recorded in the
service recorded in the beneficiary’s Beneficiary’s accounts,
accounts, excluding any ineligible cost
or costs included in other budget
categories.

Art. The actual costs may be adjusted by 98 In case of budget or estimated

6.2.D.5 the beneficiary on the basis of elements:
budgeted or estimated elements. Those
elements must be relevant for a) Must be relevant for calculating the
calculating the costs, reasonable and costs: The application of any estimated
correspond to objective and verifiable element has to be motivated and duly
information; justified in order to obtain an accurate
unit cost.

b) Must be reasonable: The resultant

unit costs should comply with the
principles of sound financial
management (economy, efficiency and
effectiveness).
In particular they should not have a
major role in the unit costs calculation
(+/- 5%)

c) Must correspond with the objective

and verifiable information: Auditors
should verify the existence of written
supporting documentation that
corresponds with the estimated
elements used (e.g. external sources,
historical data, signed agreements,
etc.). This documentation should be
complete and reliable.
Art. Not eligible: cost elements ineligible 99 Verify that the calculation does not
6.2.D.5 under the GA, costs of resources not include cost elements ineligible under
belonging to the beneficiary and which the GA, costs of resources not
it uses free of charge, costs already belonging to the beneficiary & which it
included in other budget categories). uses free of charge, and costs already
included in other budget categories.
Art. (d) the unit cost excludes any 100 Verify that the unit cost excludes any
6.2.D.5 costs of items which are not directly costs of items which are not directly
linked to the production of the invoiced linked to the production of the invoiced
goods or service. goods or service.

79
 GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. If a cost item is not used exclusively for 101 Verify if a cost item is not used
6.2.D.5 the internally invoiced good or service, exclusively for the internally invoiced
only the share used for the good or good or service, only the share used for
service may be counted (the percentage the good or service is counted.
taken must be substantiated by In order to verify the share used for the
persuasive evidence). If necessary, the good or service, this percentage must
unit cost must be adjusted to remove be substantiated through: Access
elements allocated to the unit cost records, Time records, 'Log record'
indirectly, i.e. through cost (computer based systems), Laboratory
drivers/allocation keys based on other registers, Technical descriptions or
cost items included in the unit cost (e.g. Management decision of use.
for a clean room: the costs of the
human resources department charged
to the unit cost as a fixed amount per
employee assigned to the clean room;
or power supply costs allocated to the
clean room on the basis of the square
meters it occupies).

Final General Control

GA Spec.
Condition to be checked N. General procedure to be performed
Art. Proc.
Art. FINAL GENERAL CONTROL 102 In cases in which the procedures listed above
6.1.D have been carried out successfully but the
auditor, during the execution of these
procedures, came across facts and
documents which put into question the
compliance of the costs with the eligibility
criteria foreseen in the H2020 grant
agreement this information should be
reported accompanied with adequate
supporting information.

80
E. INDIRECT COSTS
GA General procedure
Condition to be checked N.
Art. to be performed
Art. Indirect Costs covers all costs for the action that are not 1 Verify that the Beneficiary
6.2.E directly linked to it. calculated correctly the indirect
The costs must fulfil the general conditions for flat-rate costs.
costs to be eligible (i.e. costs to which the flat-rate is applied
must be eligible, correct calculation, etc.; see Article 6.1(c))

They must be calculated by applying the 25 % flat-rate to

the beneficiary’s eligible direct costs, minus:
- subcontracting costs (see Article 13)
- costs of in-kind contributions incurred by third parties
outside of the beneficiary’s premises
- costs of providing financial support to third parties
- costs from specific cost categories (unit or lump-sum costs)
that include indirect costs (e.g. ‘costs for energy efficiency
measures in buildings’, ‘access costs for providing trans-
national access to research infrastructure’ and ‘costs for
clinical studies’).
Art. Combining H2020 & other EU grants 2 Enquire if the Beneficiary
6.2.E Beneficiaries that also receive an EU operating grant can receives an operating grant
NOT declare any indirect costs for the reporting period(s) financed by the EU or Euratom
covered by the operating grant, unless they are able to budget or if such grants are
demonstrate cost separation (i.e. that the operating grant included in the revenues.
does not cover any costs that may be claimed under the
action). In case the Beneficiary received
Operating grants are annual grants to finance the operation an EU operating grant verify that
and running costs of an entity; the Beneficiary can demonstrate
cost separation (supported by
To demonstrate cost separation, the following conditions analytical accounting, accounting
must be fulfilled: records and allocation of costs).
- the operating grant may NOT cover 100% of the
beneficiary’s annual budget (i.e. it may not be a full Verify that the allocation of
operating grant) costs leads to a fair, objective
- the beneficiary must use analytical accounting which and realistic result considering
allows for a cost accounting management with cost the principles of sound financial
allocation keys and cost accounting codes AND must apply management (economy,
these keys and codes to identify and separate the costs (i.e. efficiency and effectiveness) and
to allocate them to either the action grant or the operating supported with sufficient audit
grant) evidences.
- the beneficiary must record:
 all costs incurred for the operating grant (i.e.
personnel, general running costs and other
operating costs linked to the WP) and
 all costs incurred for the action grants
(including the indirect costs linked to the action)
- the allocation of the costs must be done in a way that
leads to a fair, objective and realistic result.

Beneficiaries that cannot fulfil these conditions must EITHER:

- terminate the operating grant, in order to sign the action
grant with indirect costs
- keep the operating grant, but sign the action grant without
indirect costs

81
F. SPECIFIC COST CATEGORIES
Costs for clinical studies
This IAP was elaborated based on the COMMISSION DECISION of 25.11.2016 "modifying the Commission
decision of 7.3.2014 authorising the reimbursement on the basis of unit costs for actions requiring the
conduct of the clinical studies under 'Societal Challenge 1: Health, Demographic Change and Wellbeing' of the
Horizon 2020 Framework Programme " (C(2016) 7553).
GA Art. Condition to be checked N. General procedure to be performed
C(2016) A ‘clinical study’ is defined for the purpose 1 Obtain the list of studies for which specific unit
7553 of this decision as any clinical research costs are declared by the beneficiary.
ANNEX.1 involving a substantial amount of work
related to the observation of, data Sample: Select for testing all the items with a
collection from, or diagnostic or value higher or equal to 10% of the total costs
therapeutic intervention on multiple or declared (Specific cost category - F.2) and add
individual patients or study participants. It randomly additional items until you reach
includes but is not limited to clinical either 50% coverage or a maximum number of
studies and clinical trials in the sense of 15 items (a minimum of 5 items must be
the Clinical Trials Regulation EU No selected unless the population is less than 5).
536/2014 and, in so far as it remains
applicable, the Clinical Trials
Directive 2001/20/EC.
C(2016) The unit costs shall be specified in the 2 Obtain a breakdown of the calculation of
7553 grant agreement to be used throughout specific unit costs declared by the beneficiary.
ANNEX.1 the duration of the action.
Verify that declared eligible costs are
consistently calculated with the amount per
unit is set out in Annex 2 of the Grant
Agreement.

C(2016) However, the unit cost can be modified 3 Enquire if there has been any amendment to
7553 through an amendment to the grant grant agreement that modify the unit costs.
ANNEX.2 agreement in the following cases:
- if there is a change in the protocol (e.g.
due to requests from competent
authorities, regulatory agencies or ethics
committees) during the implementation of
the action which results in a change of the
estimation of resources needed to
calculate the unit costs. In such a case, the
Commission may ask the advice of
independent experts for the assessment of
the necessity of the resources.
- if an error occurred in the identification
of costs recorded in the beneficiary's
certified or auditable accounts for year N-
1 (last closed financial year at the time of
submission of the proposal) or wrong
application of points (a) to (d) below .
C(2016) Costs of clinical studies shall be eligible if 4 For selected studies recalculate the amount of
7553 they correspond to the amount per unit set eligible costs using the amount per unit set out
ANNEX.1 out in Annex 2 to the grant agreement in Annex 2 to the Grant Agreement multiplied
multiplied by the number of actual units by the audited actual eligible number of units.
(patients or subjects) included in the
clinical studies conducted under the action. Establish the actual eligible number of units
and compare it with the number of actual units
declared.

82
GA Art. Condition to be checked N. General procedure to be performed
C(2016) The Commission has the right to verify 5 For the selected studies, obtain the list of
7553 that these costs comply with the patients/participants that were declared by the
ANNEX.2 requirements defined in points (a) to (d) beneficiary as actual units.
below and to correct the unit costs in case
of noncompliance. Verify that:
- They were selected for participating in the
study
- There is documented evidence that they
participated in the study
- They participated in the study within the
eligibility period

C(2016) The costs of clinical studies according may 6 Verify that the costs claimed correspond with
7553 be determined according to the following only one of the forms:
ANNEX.1 forms: (i) Unit costs per patient or study participant
(i) Unit costs per patient or study calculated on the basis of their historical data,
participant calculated on the basis of their or
historical data, or (ii) Cost actually incurred
(ii) Cost actually incurred.

For the costs of personnel directly

assigned to the conduct of clinical studies,
each beneficiary or third party may only
choose one of the forms (i) or (ii).

For [cost of consumables specifically used

for the conduct of the clinical study, costs
of the medial equipment specifically used
for the conduct of the clinical study and
costs of other specific contracts necessary
for conduct of the clinical study],
beneficiaries and third parties may choose
either of the forms (i) or (ii) for each cost
item.

The choice of form of costs (unit costs or

actual costs per cost category or sub-
category) has to be made at the time of
the proposal submission. The resulting unit
costs shall also be included in the grant
proposal and in the Annex 2 to the grant
agreement.

83
GA Art. Condition to be checked N. General procedure to be performed
C(2016) The beneficiary shall use as historical 7 Verify whether the beneficiary has used the
7553 costs the costs recorded in its certified or accounting data for the determination of the
ANNEX.2 auditable profit and loss accounts for year unit costs set out in Annex 2 to the grant
N-1 (last closed financial year at the time agreement. In relation to the following costs:
of submission of the grant application). (a) Personnel costs of doctors and other
medical personnel and technical personnel
(including data managers) directly assigned to
the conduct of the clinical study;

(b) Costs of consumables specifically used for

the conduct of the clinical study;

(c) Costs of the medical equipment specifically

used for the conduct of the clinical study,
corresponding to:
- the depreciation costs
- the other costs of service contracts
necessary for their functioning (including
specific cleaning, maintenance and repair);

(d) Costs of other specific service contracts

necessary for the conduct of the clinical study
(including data analysis, if subcontracted);

C(2016) - Indirect costs of the clinical study 8 Verify that the indirect costs are calculated by
7553 applying a flat rate of 25 % of the sum of the
ANNEX.2 unit cost components referred to in points (a),
(b) and (c) above (excluding the unit cost
component referred to in point (d) above and
the costs of resources made available by third
parties which are not used on the premises of
the beneficiary, as well as financial support to
third parties.

Review the calculation of indirect costs in the

Financial Statement(s) of the action and verify
that the 25% flat rate is not applied on top to
the unit costs for clinical studies.

84
Costs for energy efficiency measures in buildings
This IAP was elaborated based on the COMMISSION DECISION of 10.12.2013 " authorising the use of
reimbursement on the basis of unit costs for energy efficiency measures in buildings under the Energy
Challenge actions of the Horizon 2020 Framework Programme" (C(2013)8196).

GA Art. Condition to be checked N. General procedure to be performed

C(2013) The following shall be considered “additional 1 Obtain the list of energy efficiency
8196 energy efficiency measures”: measures in buildings for which specific
ANNEX.1 (a) for new buildings: those measures which are unit costs are declared by the
implemented to make the building more energy beneficiary.
efficient than would have been required under
the applicable national legislation;
(b) for refurbished buildings: those measures Sample: Select for testing all the items
which are implemented to make the building with a value higher or equal to 10% of
more energy efficient than would have been the total costs declared (Specific cost
required under the applicable national category - F.2) and add randomly
legislation or than would have been the case for additional items until you reach either
the refurbishment of such a building using 50% coverage or a maximum number
current practices if there is no national of 15 items (a minimum of 5 items
regulation applicable. must be selected unless the population
is less than 5).

C(2013) The specifications per type demonstration 2 For a selected sample, contact the
8196 building are set out in the technical annex of the operational officer and obtain the
ANNEX.2 grant agreements (Annex 1). For the calculation handover certificate(s), certifying the
of the Union contributions, the periodic reports actual specifications of the buildings
are a prerequisite for any payment based on constructed or refurbished their surface
unit costs. Those reports shall be accompanied area and address.
by 'handover certificate' certifying the actual
specifications of the buildings constructed or Verify that declared eligible costs are
refurbished their surface area and address. The calculated with a correct amount per
certificate is signed by a competent person from unit.
the consortium.

C(2013) The categories of eligible costs covered by the 3

8196 unit costs are the following: For the selected sample, obtain the
ANNEX.1 – Costs of purchasing equipment, infrastructures breakdown of costs including in the
and other assets directly necessary for the calculation of the specific unit cost
demonstration of additional energy efficiency declared by the beneficiary.
measures in buildings (e.g. costs of purchasing
elements to build or refurbish buildings such as Verify that it only includes eligible costs
new isolation, new ventilation system, windows, (excluding indirect costs and fluids).
doors, heating elements, system controlling the
system);
– Costs of subcontracting the works necessary
for the demonstration of additional energy
efficiency measures in buildings.

Indirect costs for the demonstration of

additional energy efficiency measures in
buildings are not eligible

Fluids are not eligible either.

85
GA Art. Condition to be checked N. General procedure to be performed
C(2013) The unit cost applicable to the demonstration of 4 For the selected sample, verify that:
8196 actions involving energy efficient buildings - The demonstration project is a part of
ANNEX.3 related projects under Horizon 2020 shall: the action specified by the Grant
– apply per m² of eligible conditioned gross floor Agreement
area (excluding parts of the buildings - The eligible conditioned gross floor
which are not affected by the measures, e.g. area (excluding parts of the buildings
garages); which are not affected by the
– be calculated according to the following measures, e.g. garages) declared is
formula: {standard cost in EUR to save 1 kWh * based on actual specifications in
estimated total kWh saved per m² per year * handover certificate(s).
standard payback period in years} - The unit cost per m² is EUR {estimated
total kWh saved per m² per year
determined at proposal level. Obtain
this amount as part of the Audit Input
File.
- Recalculate the claimed amount: m² x
unit cost x (action period months/12)

C(2013) Indirect costs for the demonstration of 5 Review the calculation of indirect costs
8196 additional energy efficiency measures in in the Financial Statement(s) of the
ANNEX.1 buildings are not eligible (the 25% flat-rate action and verify that the 25% flat rate
financing shall not apply to the eligible costs is not applied to the unit costs for
declared on the basis of unit costs for additional energy efficiency measures.
energy efficiency measures in buildings).

C(2016) Double funding is avoided by the 6 Obtain the list of EU funding received.
7553 specification/identification of eligible costs
ANNEX.4 detailed in Section 1. Compliance with the Enquire if any of the funding received
specification method of eligible costs is checked covers efficiency measures in buildings.
through controls, during the proposal evaluation
phase as well as through ex-post controls on the
existence of other Union funding sources
specifically covering the demonstration of the
same additional energy efficiency measures in
buildings
H2020 Double funding risk — Costs that are declared 7 Check that the following eligible costs
AMGA Art. as a specific unit or lump sum cost may NOT be are not included in other budget
6.2.F declared (a second time) under another budget category:
(V.4.0.1 category (for the costs that are covered, see - costs of purchasing equipment,
Page 110) below). infrastructures and other assets directly
Example: necessary for the demonstration of
The unit cost for efficiency energy measures in additional energy efficiency measures
buildings covers subcontracting costs related to in buildings (e.g. costs of purchasing
the energy efficiency measures. These cannot elements to build/refurbish buildings
be declared as subcontracting costs. By contrast, such as new isolation, new ventilation
costs for subcontracts not included in the unit systems, windows, doors, heating
cost (e.g. subcontracts required by the elements, system controlling the
implementation of the action but not related to system);
the efficiency energy measures) can be - costs of subcontracting the works
declared. necessary for the demonstration of
additional energy efficiency measures
in buildings.

86
Access costs for providing trans-national access to research
infrastructure
This IAP was elaborated based on the COMMISSION DECISION of 10.12.2013 "authorising the use of
reimbursement on the basis of unit costs for actions involving trans-national access under the Research
Infrastructures Part of the Horizon 2020 Framework Programme" (C(2013)8199).

GA Art. Condition to be checked N. General procedure to be performed

H2020 Beneficiaries that use budget category F.2 1 Verify that the Beneficiary do not claim any
AMGA Art. ‘access costs for providing trans-national cost under the budget category D.4
6.2.F access to research infrastructure’ can NOT — ‘capitalised and operating costs of large
(v.4.0.1 under the same grant — declare costs under research infrastructure’.
Page budget category D.4 ‘capitalised and
111) operating costs of large research
infrastructure’.
C(2013) In order to measure the quantity of trans- 2 Review the Beneficiary's methodology in
8199 national access to the installation supported order to identify the unit of access to the
ANNEX.3. under the Union grant the access provider will installation.
identify a unit of access to the installation.
This unit of access shall also be used to
measure the total quantity of access that the
installation provides to all its users.

C(2013) Costs for providing trans-national access to 3 Recalculate the cost claimed by multiplying
8199 research infrastructures declared by the unit cost defined in Annex 2 of the
ANNEX.1. beneficiaries on the basis of unit costs shall Grant Agreement with the number of units
be eligible if they correspond to the amount of access verified and accepted by the
per unit set out in Annex 2 to the grant audit.
agreement multiplied by the number of
actual units of access provided under the
action and if the conditions set out in Article
16.1.1 of the grant agreement are met.

C(2013) The grants under the Research Infrastructures 4 Verify that the costs claimed correspond
8199 Part of the Horizon 2020 Framework with:
ANNEX.1. Programme shall take the form of (i) unit costs calculated on the basis of
reimbursement of either of the following historical data
eligible costs for trans-national access to (ii) actual costs solely incurred for providing
research infrastructures: access to the user groups under the action.
(i) costs declared by beneficiaries on the (documented evidence)
basis of unit costs calculated on the basis of (iii) combination of (i) and (ii)
their historical data, or
(ii) costs actually and solely incurred for Verify that only one form is used for one
providing access to the user groups selected installation (i), (ii) or (iii).
for support under the action, or
(iii) costs declared by beneficiaries on the
basis of a combination of the forms of costs
referred to in points (i) and (ii), if part of the
eligible access costs, in particular eligible
costs for the specific support to users, varies
significantly between users.
Only one of the forms referred to in points (i),
(ii) and (iii) may be used for one installation.
No alternative use is allowed for one
installation.

87
GA Art. Condition to be checked N. General procedure to be performed
C(2013) The unit cost shall be defined on the basis of 5 Enquire if the Beneficiary has obtained any
8199 the average over the last two years of the external or independent certification on the
ANNEX.3. annual total access costs to the installation, unit costs calculation.
for the categories covered by the unit cost,
divided by the average over the last two Verify that the unit costs are calculated
years of the total quantity of access to the based on historical actual data, over the
installation annually provided, as follows: last 2 years (excluding any period were the
Unit cost = (average annual total access costs installation was not usable).
to the installation /
average total quantity of access to the
installation annually provided)
The average amounts shall be based on
certified or auditable historical data of the
beneficiary (or the linked third party) over the
last 2 years (years N-1 and N-2) and
allocated to the concerned installation
according to the beneficiary’s usual cost
accounting practices. The average over the
last two years of the access costs and
quantity of access to the installation shall not
include periods where the installation was not
usable because out of order, or under repair
or maintenance.
In exceptional and duly justified cases, the
Commission may agree to use a different
reference period.

C(2013) The ‘total quantity of access to the 6 Verify the actual use of the infrastructure
8199 installation’ shall include all the units of with records of access to the research
ANNEX.3. access annually provided by the installation, infrastructure during the reference period.
included access financed by the Union under
previous grant agreements, if any.

88
GA Art. Condition to be checked N. General procedure to be performed
C(2013) Are eligible access costs: 7 Verify that the pool of costs included in the
8199 - Direct costs for providing access to the calculation of the unit costs included only
ANNEX.1. installation: direct eligible costs, excluding capital
• Personnel cost of administrative, technical investments (including rental, lease or
and scientific staff directly assigned to the depreciation costs), travel and subsistence
functioning of the installation and to the costs.
support of the users.
• Costs of contracts for maintenance and
repair (including specific cleaning, calibrating
and testing) specifically awarded for the
functioning of the installation (if not
capitalised).
• Costs of consumables specifically used for
the installation and the research work of the
users.
• Costs of contracts for installation
management, including security fees,
insurance costs, quality control and
certification, upgrading to national and/or EU
quality, safety or security standards (if not
capitalised) specifically incurred for the
functioning of the installation.
• Costs of energy power and water supplied
for the installation.
• Costs of general services when they are
specifically included in the provided access
services (library costs, shipping costs).
• Costs of software licence, internet
connection or other electronic services for
data management and computing when they
are needed to provide access services.
• Costs of specific scientific services included
in the access provided or needed for the
provision of access.

89
GA Art. Condition to be checked N. General procedure to be performed
C(2013) Are eligible access costs: 8 Verify that the pool of costs included in the
8199 - Indirect costs for providing access to the calculation of the unit costs included only
ANNEX.1. installation, indirect eligible costs, excluding capital
but excluding: investments (including rental, lease or
- All contributions to the capital investments depreciation costs), travel and subsistence
of the infrastructure (including rental, costs.
lease or depreciation costs of buildings as
well as depreciation and lease of Verify that the eligible indirect costs are
instrumentation). Those costs are not equal to 25% of the direct costs referred to
eligible for the provision of access under above (amounts for the categories taken
the Research Infrastructures Part of the into account in the unit costs, i.e. excluding
Horizon 2020 Framework Programme, the categories reimbursed on an actual
- Travel and subsistence costs to support the cost basis) minus any costs of
visits of users. Those costs shall be subcontracting (amounts referred to above
reimbursed on the basis of eligible costs for the categories “costs of contracts for
actually incurred under the cost category maintenance and repair”, “costs of
“other direct costs”. contracts for installation management”,
“costs of scientific services” and “cost for
other electronic services”).

Review the calculation of indirect costs in

the Financial Statement(s) of the action
and verify that the 25% flat rate is not
applied on top to the unit costs for trans-
national access.

90
Fusion programme
This IAP was elaborated based on the COMMISSION DECISION of 10.12.2013 "authorising the use of
reimbursement on the basis of unit costs for Fusion programme co-fund action under the Research and
Training Programme of the European Atomic Energy Community (2014-2018)" (C(2013)8201).

GA Art. Condition to be checked N. General procedure to be performed

C(2013) The grant for the Euratom Fusion 1 Verify that the costs claimed correspond with:
8201 programme co-fund action shall (a) on the basis of unit costs for the eligible costs
ANNEX.(1) take the form of reimbursement of of mobility of personnel;
eligible costs declared by (b) on the basis of unit costs for the eligible costs
beneficiaries: of fellowships for researchers;
(a) on the basis of unit costs for (c) either on the basis of unit costs or as costs
the eligible costs of mobility of actually incurred for the eligible access costs to
personnel; research infrastructures. For one installation, the
(b) on the basis of unit costs for eligible access costs shall be declared either on the
the eligible costs of fellowships for basis of unit costs or as actually incurred. No
researchers; combination is allowed.
(c) either on the basis of unit costs
or as costs actually incurred for the
eligible access costs to research
infrastructures. For one installation,
the eligible access costs shall be
declared either on the basis of unit
costs or as actually incurred. No
combination is allowed.

Other categories of eligible costs

shall be reimbursed on the basis of
eligible costs actually incurred or,
for other direct personnel costs, on
the basis of unit costs or, for
indirect costs, flat-rate financing.

C(2013) (a) Mobility unit costs 2 Verify that the Costs of mobility of personnel
8201 declared as unit costs:
ANNEX.(1.1) (i) relate to the secondment of an individual
(employee of the beneficiary)
(ii) the secondment is made to a location other
than the individual's place of employment and to
one of the following:
- an organisation where the individual
takes part in experiments using a research
infrastructure of that organisation;
- another beneficiary where the individual
carries out research activities described in
Annex 1 or 7 of the grant agreement, or
- a joint support unit created by the
beneficiaries under the action;
(iii) correspond to the amount per unit set out in
the estimated budget of the action (Annex 2 and
Annex 2a to the grant agreement) multiplied by the
number of actual days or months of secondment;
and
(iv) have been fully incurred for the benefit of the
seconded individual.

91
 GA Art. Condition to be checked N. General procedure to be performed
C(2013) (a) Mobility unit costs 3 Verify that the unit costs of mobility of personnel
8201 include only the following categories of costs:
ANNEX.(1.1) - a daily subsistence allowance to cover for the
costs of living payable to the individual,
- a monthly subsistence allowance payable to the
individual,
- a monthly family allowance (per child) to be paid
to the seconded personnel that has children
following a primary or secondary education courses
to cover for the tuition fees of the children.
Verify that no management costs for the mobility
of personnel are included in the calculation (these
shall be reimbursed on the basis of eligible costs
actually incurred under other categories of costs).
Verify that the 25% flat-rate financing for indirect
costs is not applied to the unit costs of mobility of
personnel.
C(2013) (a) Mobility unit costs 4 Verify that the allowances are paid according to the
8201 amounts provided by the Commission Decision C
ANNEX.(3.1) (2013)8196 and included in Annex 2a of the
relevant Grant Agreement:
- Daily subsistence allowance is of EUR 127,65.
- Monthly subsistence allowance varies according
to the distance between place of employment and
place of secondment – see relevant tables.
- Family allowance is of EUR 252,81 per month.

The unit costs will be expressed in person-months

and corresponding to the country-specific
correction factor of 100% applicable to Belgium
and Luxembourg and to the country-specific
correction factors for all other countries as included
in Annex 2a of the relevant Grant Agreement.
C(2013) (b) Unit costs for fellowships for 5 Verify that the costs of fellowships for researchers
8201 researchers declared as unit cost:
ANNEX.(1.2) (i) correspond to the amount per unit set out in the
estimated budget of the action (Annex 2 and
Annex 2a to the grant agreement) multiplied by
the number of actual months spent by the fellows
on the research training activities;
(ii) have been fully incurred for the benefit of the
fellows.

92
 GA Art. Condition to be checked N. General procedure to be performed
C(2013) (b) Unit costs for fellowships for 6 Verify that the unit costs for fellowships for
8201 researchers researchers only cover the following categories of
ANNEX.(1.2) costs:
- living allowances payable to the individual early-
stage or experienced researchers recruited under
an employment contract/ contract with full social
security coverage by the beneficiary and complying
with the social security legislation applicable. These
amounts include all compulsory deductions under
national applicable legislation,
- a mobility allowance payable to the individual
researcher to cover additional mobility related
costs such as travel and accommodation,
- a family allowance payable to the individual
eligible researcher to reduce family-related
obstacles to researcher mobility.
The management costs for the fellowships for
researchers shall be reimbursed on the basis of
eligible costs actually incurred.
The 25% flat-rate financing for indirect costs shall
not apply to the unit costs for the fellowships for
researchers.
C(2013) (b) Unit costs for fellowships for 7 Verify that:
8201 researchers - the living allowance for experienced researchers
ANNEX.(3.2) eligible for an individual fellowship is fixed at EUR
4 650. The living allowance for early-stage
researchers is fixed at EUR 3 110.
(the above living allowance is subject to a country -
specific correction coefficient).
- The mobility allowance which is fixed at EUR 600.
- The family allowance which is fixed at EUR 500.

C(2013) (c) Unit costs of access to research 8 Verify that the costs of access to research
8201 infrastructures infrastructure declared one the basis of unit costs
ANNEX.(3.3) shall correspond to the amount per unit set out in
the estimated budget of the action (Annex 2 to the
grant agreement) multiplied by the number of
actual units of access provided to other
beneficiaries.

93
 GA Art. Condition to be checked N. General procedure to be performed
C(2013) (c) Unit costs of access to research 9 Verify that the unit costs of access to research
8201 infrastructures infrastructures includes only eligible costs:
ANNEX.(1.3) - Direct costs for providing access to the
installation:
• personnel costs of administrative, technical and
scientific staff directly assigned to the functioning
of the installation and to the support of the users,
• costs of contracts for maintenance and repair
(including specific cleaning, calibrating and testing)
specifically awarded for the functioning of the
installation,
• costs of consumables specifically used for the
installation and the research work of the users,
• costs of contracts for installation management,
including security fees, insurance costs, quality
control and certification, upgrading to national
and/or EU quality, safety or security standards
specifically incurred for the functioning of the
installation;
• costs of energy power and water supplied for the
installation,
• costs of general services when they are
specifically included in the provided access services
(library costs, shipping costs),
• costs of software licence, internet connection or
other electronic services for data management and
computing when they are needed to provide access
services,
• costs of specific scientific services included in the
access provided or needed for the provision of
access,
• depreciation costs of the equipment, buildings and
other assets (new or second-hand) that are part of
the installation and that were not purchased or
built using
Union funds as well as the costs of renting or
leasing the equipment, buildings and other assets
that are part of the installation,
- Indirect costs for the access to the installation,
but excluding
- travel and subsistence costs to support the visits
of users. Those costs shall be reimbursed on the
basis of eligible costs actually incurred under the
cost category "other direct costs".

94
 GA Art. Condition to be checked N. General procedure to be performed
C(2013) (c) Unit costs of access to research 10 Verify that the unit cost are defined on the basis of
8201 infrastructures the average over the last two years of the annual
ANNEX.(1.3) total access costs to the installation for the
categories covered by the unit costs, divided by the
average over the last two years of the total
quantity of access to the installation annually
provided.
The average amounts shall be based on certified or
auditable historical data of the beneficiary (or the
linked third party) over the last 2 years (years N-1
and N-2) and allocated to the concerned
installation according to the beneficiary’s usual
cost accounting practices in case the installation
has less than 2 years of operation. The average
over the last two years of the access costs and
quantity of access to the installation shall not
include periods where the installation was not
usable because out of order, or under repair or
maintenance.

95
RECEIPTS
GA Art. Condition to be checked N. General procedure to be performed
Art. Reduction due to the no-profit rule: 1
5.3.3 The grant must not produce a profit. 'Profit' Obtain from the Beneficiary the detail of
means the surplus of the amount obtained project receipts and reconcile this with the
following [the application of the reimbursement breakdown of receipts supporting the
rates to the eligible costs (step 1)] and the limit Financial Statements.
to the maximum grant agreement plus the
action's total receipts (step 2), over the action's
total eligible costs.
Receipts will be taken into account by the
Commission / Agency only at the moment of the
payment of the balance (i.e. the final payment at
the end of the action).
They must be declared in the final report.
Art. 5.3 All receipts have to be: 2 Verify whether the receipts are
- established (i.e. revenue that has been - established (i.e. revenue that has been
collected AND entered in the accounts); OR collected AND entered in the accounts); OR
- generated (i.e. revenue that has not yet been - generated (i.e. revenue that has not yet
collected, but which has been generated) OR been collected, but which has been
- confirmed (i.e. revenue that has not yet been generated) OR
collected, but for which the beneficiary has a - confirmed (i.e. revenue that has not yet
commitment or written confirmation) during the been collected, but for which the
action duration. beneficiary has a commitment or written
confirmation) during the action duration.
Art. Income generated by the action 3
5.3.3.a)
The following are considered receipts: Verify completeness of the disclosed
(a) income generated by the action; if the income project receipts by identifying any receipt
is generated from selling equipment or other generated by the action such as:
assets purchased under the Agreement, the a) sale of equipment or assets
receipt is up to the amount declared as eligible bought for the project (limited to the
under the Agreement; claimed eligible cost of purchase);
For example admission fee to conferences. b) admission fee to a conference
carried out by the consortium;
The following are however not considered c) sale of the proceedings of a
receipts: conference;
(a) income generated by exploiting the action’s
results (see Article 28); This analysis should be performed through
corroborative inquiry and review of the
income recorded in Beneficiary's accounts.

96
GA Art. Condition to be checked N. General procedure to be performed
Art. Financial contributions 4 Obtain the general ledger account of
5.3.3.b) received funding, grants, subsidies.
The following are considered receipts:
Verify (on sample basis) the completeness
(b) financial contributions given by third parties of the disclosed financial contributions by
to the beneficiary [or to a linked third party] assessing whether the Beneficiary has
specifically to be used for the action, and disclosed the receipts as a result of
financial contributions from third parties,
The following are however not considered which:
receipts: - were given specifically to be used
(b) financial contributions by third parties, if they for the project;
may be used to cover costs other than the - may only be used to cover eligible
eligible costs (see Article 6); costs (if they may be used to finance
c) financial contributions by third parties with no ineligible costs (e.g. exchange losses) than
obligation to repay any amount unused at the the amount does not constitute a receipt);
end of the period set out in Article 3. - require the Beneficiary to repay
any amount unused at the end of the
project duration (if there is no such
obligation, then the ENTIRE amount is NOT
considered a receipt).

As receipts are only contributions from

third parties, ensure that the Beneficiary
did not declare as receipt a financial
contribution by another Beneficiary.

Art. In-kind contributions 5 Verify (on sample basis) the completeness

5.3.3.c) of the disclosed in-kind contributions by
The following are considered receipts: ensuring that the Beneficiary has
disclosed the receipts as a result of in-kind
(c) in-kind contributions provided by third parties contributions from third parties, which
free of charge and specifically to be used for the were provided:
action, if they have been declared as eligible - free of charge;
costs. - to be used specifically for the
action.

Ensure that the Beneficiary declared as

receipt the amount declared as eligible
costs (the receipt is capped to the
declared eligible cost).

As receipts are only contributions from

third parties, ensure that the Beneficiary
did not declare as receipt a financial
contribution by another Beneficiary.

97
COORDINATOR ROLE
GA
Condition to be checked N. General procedure to be performed
Art.
Art. Payments to the coordinator — Distribution to 1 As stipulated in the AMGA, how and when the
21.7 the beneficiaries payments are distributed is in principle an
internal matter for the consortium. If the
The coordinator must distribute the payments coordinator does NOT comply with its
between the beneficiaries without unjustified obligations, this is in principle an issue to be
delay. resolved within the consortium.
Only if the coordinator is terminated, the
Commission / Agency/JU (and especially the
Guarantee Fund) will intervene.
Nonetheless, the auditor will carry out the
following audit steps:

- If the audit scope covers the final period of

the project, obtain the Report on the
Distribution of Payments (if it was requested
by the Commission).

- If the audit scope does not cover the final

period of the project, obtain the EU letters
regarding the pre-financing and interim
payments.

- Obtain the Consortium Agreement (CA).

- Ask the Coordinator to provide a detail of

payments (amount, date and bank reference)
to the different Beneficiaries.

- Verify whether the distribution of funds

towards beneficiaries is in line with the Report
on the Distribution of Payments, if applicable
(see H2020 AMGA v.4.0.1 Page 196).

- Verify this detail for correctness on sample

basis calculated over all audited periods
together (so not per period or interim
payment). Sample size: lowest of 15 payments
or 50% of total amount of payments made
during the audited periods.

98
GA
Condition to be checked N. General procedure to be performed
Art.
Art. (b) The coordinator must: 2 Verify that the coordinator did not delegate or
41.2 (i) monitor that the action is implemented subcontract any of the tasks detailed under
properly (see Article 7); Article 41.2;
(ii) act as the intermediary for all communications
between the beneficiaries and the Exception for delegation of payments and Report
[Commission][Agency] (in particular, providing the on the Distribution of Payments:
[Commission][Agency] with the information Verify whether, if the coordinator delegated the
described in Article 17), unless the Agreement payments or Report on the Distribution of
specifies otherwise; Payments to Beneficiaries to a third party, that:
(iii) request and review any documents or - the Beneficiary is a secondary or higher
information required by the [Commission][Agency] education establishment or public body; and
and verify their completeness and correctness - the Beneficiary gave a formal "authorisation to
before passing them on to the administer" to the third party mentioned in
[Commission][Agency]; Article 41.2 OPTION.
(iv) submit the deliverables and reports to the - the third party is affiliated, controlled or set up
[Commission][Agency] (see Articles 19 and 20); by the coordinator in order to handle its
(v) ensure that all payments are made to the administrative affaires, including receiving and
other beneficiaries without unjustified delay (see administering EU funds.
Article 21);
(vi) inform the [Commission][Agency] of the Exception for ERICs to exceptionally delegate the
amounts paid to each beneficiary, when required following coordination tasks to one of its
under the Agreement (see Articles 44 and 50) or members:
requested by the [Commission][Agency]. If the coordinator is an ERIC without own
The coordinator may not delegate or subcontract resources and it delegated tasks to one of its
the above-mentioned tasks to any other members, verify that only the following tasks
beneficiary or third party (including linked third were delegated:
parties). - monitoring that the action is implemented
properly; or
Specific cases (coordinator): - acting as intermediary for communications;
Authorisation to administer — Coordinators that or
are secondary or higher education establishments - requesting and reviewing documents or
and public bodies may exceptionally delegate the information required and verify completeness
administration of the payments to another legal and correctness; or
entity (third party), in most cases a foundation. - submitting deliverables and reports.
The third party must fulfil the following conditions:
- they must have been granted the ‘authorisation
to administer’
AND
- it must be affiliated, controlled or set up by the
coordinator in order to handle its administrative
affairs (and those must include receiving and
administering EU funds).

ERICs (European Research Infrastructure

Consortia):
Beneficiaries that are ERICs and do not have their
own resources may exceptionally delegate the
following coordination tasks to one of its
members:
- monitor that the action is implemented properly
(see Article 7);
- act as intermediary for communications (see
Article 17);
- request and review documents or information
required and verify completeness and correctness;
- submit deliverables and reports (see Articles 19
and 20);

99
SME – Phase 2
Applicable only for H2020 MGA SME Ph 2.

A. Direct Personnel Costs

GA General procedure to be
Condition to be checked N.
Art. performed
Art. These costs must be declared on the basis of the unit cost 1 Verify that the correct specific
6.2.A.4 (hourly rate) fixed by Commission Decision C(2013) 819718 rate for each individual has
/A.5 and set out in Annex 2 and 2a of the GA. The precise unit cost is been used.
not pre-fixed by the Decision; the ‘amount per unit’ (hourly rate)
must be calculated for each individual before signature of the For GAs signed up to March
GA according to the following formula: Amount per unit = {{EUR 2016 the costs are set out in
4,650/143 hours} multiplied by {country-specific correction Annex 2 and Annex 2a is not
coefficient of the country where the beneficiary is established}} included in the GAs. Annex 2a
The country-specific correction coefficient is the one set out in is available in SME Instrument
the Main Work Programme — MSCA in force at the time of the project only after March 2016.
call. Example: A German SME owner not receiving a salary will
calculate the hourly rate as follows: EUR 4.650/143 * 98.8% =
EUR 32,13 /hour. In practice, the declaration of costs for SME
owners and beneficiaries that are natural persons is very simple
and almost completely automatised: The beneficiaries must
only indicate the number of hours worked on the action and the
costs are then automatically calculated by the IT system.
In line with Article 5.2 a) MGA – SME Ph 2, the costs must be
declared on the basis of the amount per unit set out in Annex 2.

B. Subcontracting
GA
Condition to be checked N. General procedure to be performed
Art.
Art. The specific eligibility conditions foreseen in 2 Obtain and review the signed Grant
13.1.1 an option in the Grant Agreement for Agreement(s). Confirm that if specific
subcontracting above a defined threshold provisions are foreseen in case the
should be complied with. subcontracting costs exceed the threshold
Please note that the relevant clause on the defined in the GA the latter are complied
threshold is missing from the signed GAs of with.
the SME Instrument. The GAs signed in the
second half of 2016 are expected to include
this provision. In both cases there is no
change in the General procedure to be
performed proposed.
Art. If the subcontracting was awarded on the 3 If the subcontracting was awarded on the
13.1 basis of an existing framework contract the basis of an existing framework contract
name of the subcontracting supplier was confirm that the original signed
listed in Annex I Description of Work of the subcontracting agreements are signed with
audited Grant Agreement(s). the legal entity stated in Annex 1 Description
of Work of the audited Grant Agreement(s). If
the Beneficiary awarded subcontracting on
the basis of an existing framework contract,
but the name of the subcontractor is
different from the one specified in Annex 1
request the Beneficiary to provide the
Agency's approval (amendment).

100
 GA
Condition to be checked N. General procedure to be performed
Art.
MGA The Agency will assess compliance with best 4 Review Annex 1 (including any amendments)
SME value for money during the evaluation of the and identify any subcontracts (i.e. the name
Ph2 – proposals (amendment requests to of the subcontractor, the task(s) to be
Art. 13 include/modify subcontractors). . Assurance subcontracted and the price of
can only by given on subcontracts that are subcontracting) for which the assurance given
described in sufficient detail in the proposal. by the Agency is explicitly mentioned.
For already awarded subcontracts: action
task(s) that are subcontracted; key Review if any subcontracting items from your
information on the award procedure; name of sample (as selected in procedure 7 in the IAP)
subcontractor; price and object; explanation are related to subcontracts for which the
why the subcontractor and the price are assurance was explicitly given by the Agency.
appropriate. Annex 1 will explicitly identify the
subcontracts for which assurance is given by For sampled items which are covered by the
the Agency. Agency's assurance verify that the name of
the subcontractor, subcontracted task(s) and
the price of subcontracting are identical to
those described in the Annex 1. In case of
differences request the Beneficiary to provide
the Agency's approval (amendment).
MGA The Agency will assess compliance with best 5 Review Annex 1 (including any amendments)
SME value for money during the evaluation of the and identify any procurement procedure for
Ph2 - proposals. Assurance can only by given on which the assurance given by the Agency is
Art. 13 subcontracts that are described in sufficient explicitly mentioned.
detail in the proposal. For future subcontracts:
action task(s) to be subcontracted; estimated Review if any subcontracting items from your
budget; procedure that will be followed to sample (as selected in procedure 7 in the IAP)
ensure best value for money. Annex 1 will were subcontracted by the beneficiary using
explicitly identify the subcontracts for which the procedure on which the explicit assurance
assurance is given by the Agency (for these was given by the Agency.
subcontracts, beneficiaries have assurance
that compliance with best value for money Verify that the procedure as described in
will not be challenged in audits – unless it Annex 1 (amendments) was followed by the
turns out that the beneficiary did not follow Beneficiary.
the procedure described or concealed
information for the purpose of the approval).

101
ERC
Applicable only for H2020 MGA ERC.

A. Direct Personnel Costs

GA Art. Condition to be checked N. General procedure to be performed
Art. They must be actually incurred by the 1 Select for testing a sample of persons based
6.1.(i) Beneficiary on the following method:
1) If the total personnel costs declared are
below the planning materiality level (5% of
total costs declared) select for testing only
the person with the highest amount declared.

2) If the total personnel costs declared are

above the planning materiality level (5% of
total costs declared) select for testing all the
items with a value higher or equal to 10% of
the costs declared for personnel costs and
add randomly selected persons until you
reach either 50% coverage of the personnel
costs or a maximum number of 15 persons.
A minimum of 5 persons must be selected
unless the population is less than 5.

For a large portion of ERCEA projects, the

personnel cost for one person (e.g. the PI)
represents 50% of personnel costs declared.
In cases where the sampled costs relate to 1
individual only, extend a sample by adding
one more individual with a different type of
employment contract (if possible).
Art.6.1 They must be incurred in connection with 2 For the Principal Investigator (PI), or in case
(iv) the action as described in Annex 1 and is not possible a sample of at least 1 Person
necessary for its implementation; per Action from the persons selected for
testing, review the CV, job profile, internet
sources (e.g.: LinkedIn, etc.), scientific
reporting and perform interviews in order to
verify that:
1) they have the necessary qualifications for
the performance of the tasks attributed to
them in the context of the H2020 action and
2) verify their involvement in the action. (e.g.:
Ask them to describe their part in the project
and the work performed, etc.).
Art.32 Main obligations (of the PI): 3 Verify that the PI comply with the minimum
requirements regarding working time on the
action (fixed in Annex 1 and 2) and working
time in an EU Member State or H2020
associated country (set out in the work
programme/call).

102
 GA Art. Condition to be checked N. General procedure to be performed
Art.6.2.A.1 Recruitment costs - Recruitment costs are 4 Identify any claimed costs related to the
generally not eligible as direct personnel recruitment procedures (job analysis,
costs, because the beneficiary is required to announcement, evaluation, selection, etc.).
have the necessary human resources to For ERC frontier research grants, recruitment
implement the action. If a beneficiary needs costs, if clearly attributable to the action, are
to recruit additional personnel during the eligible as "other direct costs" (because
action duration, the related costs would be recruitment is part of the activities of such
considered part of the entity’s normal actions).
indirect costs, which under Horizon 2020 are
covered by a 25% flat-rate of the eligible
direct costs.

103
D. Other Direct Costs
GA Condition to be checked N. General procedure to be performed
Art.
Art. Promoting of the action – visibility of EU 5 When verifying the actual existence of the
38.1.2e funding sampled assets by physical inspection, verify
Unless the [Commission][Agency] requests or whether the EU emblem is displayed and
agrees otherwise or unless it is impossible, whether for ERC grants the following wording
any communication activity related to the of the text is used:
action (including in electronic form, via social "Please note that for ERC grants the following
media, etc.) and any infrastructure, equipment wording of the text is used "This
and major results funded by the grant must: [infrastructure][equipment][insert type of
(a) display the EU emblem and result] is part of a project that has received
(b) include the following text: funding from the European Research Council
(ERC) under the European Union's Horizon
"This [infrastructure][equipment][insert type of 2020 research and innovation programme (
result] is part of a project that has received grant agreement No [number]""
funding from the European Research Council
(ERC) under the European Union's Horizon When the EU emblem is displayed together
2020 research and innovation programme ( with another emblem or logo, assess whether
grant agreement No [number]" the EU logo has appropriate prominence.

When displayed together with another logo,

the EU emblem must have appropriate
prominence.
Art. Costs charged for equipment must be 6 Verify the actual existence of the assets by
6.1.a identifiable and verifiable. physical inspection. The physical inspection
(v) for intangible assets may take form of
logging on, demonstration, interviews with
staff, etc. If the asset is located in a different
location than the one where the audit field
work takes place obtain a written
confirmation with attached digital
photo/evidence of the asset along with its
asset registration form from the technical
personnel responsible for the safeguard and
the maintenance of the asset and co-signed
by the principal investigator that the asset
exists. If assets do not exist anymore (sold,
given for free, destroyed, disposed, etc.)
inspect accounting and other documentation
to define the date on which the asset is
written-off from the asset register.
Art. Open access — Costs related to open access 7 Verify by checking the invoice and the nature
6.2 D.3 to peer-reviewed scientific publications and of the cost if is related to open access. In
research data are eligible, if the eligibility case of fees levied for a membership scheme
conditions are fulfilled. With explicit enquire if there is explicit agreement by the
agreement by the Commission / Agency, it can Commission / Agency.
also include fees levied for a membership In addition to the General procedure to be
scheme (if this is a requirement for publishing performed, take into consideration that access
in open access or if membership is a pre- to publications and to research data are
condition for significantly lower article eligible if incurred during the action duration.
processing charges). See specific conditions in ERC AMGA v.4.0.1
page 378.

ERA-NET Cofund

104
Applicable only for H2020 MGA ERA-NET Cofund.

A. Direct Personnel Costs

GA Art. Condition to be checked N. General procedure to be performed
Art. Ineligible costs (other than those not 1 In addition to the general procedures to be
6.5.(a).(i) meeting the general and specific performed, for ERA-NET Cofund the costs of
criteria) organising the calls (i.e. preparation of the call,
selection of the projects etc.) or for additional
coordination and networking activities of
beneficiaries implementing trans-national
project themselves are not eligible.

B. Subcontracting
GA Art. Condition to be checked N. General procedure to be performed
Art. Costs declared do not contain 2 Confirm that the declared costs for
6.5.(a) ineligible elements. subcontracting do not contain any of following
The eligibility of duties depends on the ineligible elements:
eligibility of the cost item to which (i) costs related to return on capital;
they are linked (i.e. in whose price they (ii) debt and debt service charges;
are included). If the item is eligible, the (iii) provisions for future losses or debts;
duty is also eligible. (iv) interest owed;
Costs to allow for the participation of (v) doubtful debts;
disabled people (e.g. costs for sign (vi) currency exchange losses;
language interpreters required for (vii) bank costs charged by the Beneficiary’s bank
dissemination events organised under for transfers from the EC;
the action) — May be eligible if they
fulfil the general and specific eligibility In addition to the General procedure to be
conditions listed under Articles 6.1 and performed, confirm that do not contain costs for
6.2. The beneficiaries must keep organising the calls (i.e. preparation of the call,
records (see Article 18) to prove in selection of the projects etc.), which are not
case of an audit, check or review the eligible under the ERA-NET grant.
actual costs incurred and that they
were necessary for the
implementation of the action.

105
D. Other Direct Costs
GA Art. Condition to be checked N. General procedure to be performed
Art. 15 ERA-NET Cofund 3 Determine through review of the financial statements if the
costs claimed relate to: A.1) costs of providing financial support
to third parties implementing trans-national projects; A.2) costs
for the implementation of the trans-national projects by the
beneficiary or B) direct coordination costs for additional
activities.

a) If the costs relate to costs of providing financial support to

third parties implementing trans-national projects: execute
specific audit procedures as outlined in IAP "Other direct costs"/
SPECIFIC CATEGORY ERA-NET COFUND: A.1. Direct Costs of
providing financial support to third parties

b) if the costs relate to costs for the implementation of the

trans-national projects by the beneficiary: for all cost categories
perform the audit procedures provided in the IAP for the
general H2020 grant agreement.

c) if the costs relate to direct coordination costs for additional

activities: execute specific audit procedures as outlined in IAP
"Other direct costs"/ SPECIFIC CATEGORY ERA-NET COFUND: B.
Direct coordination costs of additional activities
(29.000EUR/year)

A.1 Direct Costs of providing financial support to third parties

GA Art. Condition to be checked N. General procedure to be performed
Art. 15 For ERA-NET Cofund actions, 4 Obtain the list of the trans-national projects for which
the beneficiaries may provide financial support has been provided with the respective
financial support to third total costs per project. Reconcile the total of these costs
parties (i.e. pass on the EU to the amount claimed under section A.1. For amounts
support they receive via the established in other currency than the euro first convert
ERA-NET Cofund grant to the totals to euro by using the rate as specified in
recipients that are not party to Art.20.6 of the H2020 GA for ERA-NET COFUND.
the GA, also called ‘cascade Select sample of projects for testing - 1) if the population
funding’). of projects is less or equal to 5 items, all items should be
In this case, the beneficiaries’ tested; or 2) if the population is more than 15 items
activity consists in providing select for testing a maximum of 15 items. Select for
financial support, while it is the testing all the items with a value higher or equal to 10%
recipients (third parties) that of the costs declared under section A.1. Add randomly
actually implement the trans- selected projects until 50% coverage is achieved or the
national research and/or total maximum number of 15 items is reached.
innovation projects.

ERA-NET Cofund stipulates the

6 eligibility criteria.

The selection procedure must

be followed by an independent
expert observer, who must
make a report (see Article
20.2a);

106
GA Art. Condition to be checked N. General procedure to be performed
Art. 15 5 Obtain the list of final beneficiaries for each selected
project. Trace the final beneficiaries for which costs have
been claimed to the initial projects' proposals. Obtain an
understanding about eventual changes compared to the
initially foreseen final beneficiaries.
Art. 15 6 Verify that the final beneficiaries have signed the
acceptance of grants' forms.
Art. 15 7 Review the agreements between the Beneficiary and the
final beneficiaries for clauses ensuring to the European
Commission / Agency, European Court of Auditors (ECA)
and the European Anti-Fraud Office (OLAF) their rights
under Articles 22 and 23 of the Grant Agreement(s).
Art. 15 8 Verify that valid expense claim forms have been received
by the grant's Beneficiary before any reimbursement to
final beneficiaries. Reconcile the sum of the valid expense
claim forms from the final beneficiaries to the costs
claimed by project.
Art. 15 9 Obtain an overview of ex-post audits on the costs
declared by the final beneficiaries in accordance with the
national applicable rules and an overview of identified
costs' adjustments.
Trace the eventual costs' adjustments proposed by the ex-
post audits carried out according to national funding rules
to the final claim to the EC.
Art. 15 10 Verify whether EU financial support was distributed to the
final beneficiaries by tracing the payments to the grant's
Beneficiary's bank account(s).
Art. 15 11 Verify that the amounts of financial support to final
beneficiaries reconcile with the ones set forth in the
Annex 1 of the grant agreement.
Art. 15 12 Obtain evidence of national funding payments to final
beneficiaries.
Art. 15 13 Verify that the national funding payments meet the
criteria as set forth in Annex 1 of the grant agreement.

107
B. Direct coordination costs of additional activities
GA Art. Condition to be checked N. General procedure to be performed
Art. 6.2.B Direct coordination costs for 14 Verify if the beneficiary implements, partially or fully, the
additional activities are eligible, transnational project under audit.
if they correspond to the
amount per unit set out in
Annex 2a multiplied by the
number of actual years in
which the beneficiary has
carried out the ‘additional
activities’ described in Annex 1.

Beneficiaries that implement

transnational projects (partially
or fully) themselves cannot
declare direct coordination
costs for additional activities
Art. 6.2.B 15 Obtain an understanding of the additional activities
carried out. Interview staff of the beneficiary to obtain
information about the nature of the activities, obtain the
annual programs for additional activities for each year
under review, review Annex 1 of the ERA-NET grant and
the progress reports, obtain supporting documents
(meeting minutes, participants lists, presentations given
and reports produced during/after the meetings etc.).
Art. 6.2.B 16 Verify if the additional activities programmed for each
year under audit are carried out in full during the year.
Art. 6.2.B 17 1. Verify that the number of units equals the period
during which additional activities were carried out, with
the period formatted as years (e.g. 6 months = 0.5
years).

2. Verify that the claimed amount equals the number of

units x EUR 29 000.

108
Marie Skłodowska-Curie Actions
Applicable only for H2020 MGA MSCA.
GA Condition to be
N. Procedure to be performed
Art. checked
Art. COST 1 Obtain the calculation of the total number of units claimed by the
6.1 & CALCULATION: The ITN beneficiary. The costs reported must be equal to the actual number
6.2 costs claimed for of units (person-months) multiplied by the unit costs, taking into
recruited researchers, consideration that for the living allowance in ITN the country
seconded staff and correction coefficient is applicable. In addition, the family status
the institutional costs affects the family allowance in ITN (0 EUR or 500 EUR). Verify that
must comply with the the appropriate unit costs, as per the Work Programme of the year
Grant Agreement. The in which the grant was awarded, were used to calculate the total
units declared cost claim. Obtain the overall calculation and check the number of
correspond to the units with contractual documentation, payroll records, access rights,
actual number of lab books or other evidence as made available by the beneficiary, in
months spent by the order to substantiate the number of months spent by the
researchers on the researchers on the relevant action, taking into consideration the
research training limit of months (Procedure n°2).
activities (ITN).
This test is not a sample. It must be applied to 100% of the amount
claimed.

The rates for 2014 through 2017 (i.e. for projects funded from the
respective annual budgets) are:

*Family = be married / be in a relationship with equivalent status

to a marriage recognised by the legislation of the country or region
where it was formalised / have dependent children who are
actually being maintained by the researcher.
All rates above are indicated in EUR per person-month. All
recruited researchers should receive the living and mobility
allowances. Family allowances are due if the researcher has a
family at the time of recruitment and this does not change during
the fellowship even if the family situation of the researcher is
changed. If the costs for the researcher are eligible, irrespective of
any underpayments, then the Institutional costs are eligible for the
corresponding number of units. Costs not incurred during the
periods of research training activity (e.g. during maternity /
parental leave) are ineligible.
If not in EURO: daily rate of the ECB website or the average
monthly accounting rate over the reporting period, using the
currency converter on the Commission's website. For ease of
implementation the allowances can be calculated using a
conservative exchange rate if a corrective payment is made at the
end of the period.

109
 Art. COST 1 Obtain the calculation of the total number of units claimed by the
6.1 & CALCULATION: The IF beneficiary. The costs reported must be equal to the actual number
6.2 costs claimed for of units (person-months) multiplied by the unit costs, taking into
recruited researchers consideration that for the living allowance in IF the country
and the institutional correction coefficient is applicable. In addition, the family status
costs must comply affects the family allowance in IF (0 EUR or 500 EUR). Verify that
with the Grant the appropriate unit costs, as per the Work Programme of the year
Agreement. The units in which the grant was awarded, were used to calculate the total
declared correspond cost claim. Obtain the overall calculation and check the number of
to the actual number units with contractual documentation, payroll records, access rights,
of months spent by lab books or other evidence as made available by the beneficiary, in
the researchers on order to substantiate the number of months spent by the
the research training researchers on the relevant action, taking into consideration the
activities (IF). limit of months (Procedure n°2).

This test is not a sample. It must be applied to 100% of the amount

claimed.
The rates for 2014 through 2017 (i.e. for projects funded from the
respective annual budgets) are:

*Family = be married / be in a relationship with equivalent status

to a marriage recognised by the legislation of the country or region
where it was formalised / have dependent children who are
actually being maintained by the researcher.

All rates above are indicated in EUR per person-month. All

recruited researchers should receive the living and mobility
allowances. Family allowances are due if the researcher has a
family at the date of the call deadline and this does not change
during the fellowship even if the family situation of the researcher
is changed. If the costs for the researcher are eligible, irrespective
of any underpayments, then the Institutional costs are eligible for
the corresponding number of units. Costs not incurred during the
periods of research training activity (e.g. during maternity /
parental leave) are ineligible.

If not in EURO: daily rate of the ECB website or the average

monthly accounting rate over the reporting period, using the
currency converter on the Commission's website. For ease of
implementation the allowances can be calculated using a
conservative exchange rate if a corrective payment is made at the
end of the period.

110
 Art. COST 1 Obtain the calculation of the total number of units claimed by the
6.1 & CALCULATION: The RI beneficiary. The costs reported must be equal to the actual number
6.2 costs claimed for SE of units (person-months) multiplied by the unit costs. Verify that the
seconded staff appropriate unit costs, as per the Work Programme of the year in
members and the which the grant was awarded, were used to calculate the total cost
institutional costs claim. Obtain the overall calculation and check the number of units
must comply with the with contractual documentation, payment transactions, access
Grant Agreement. The rights, lab books or other evidence as made available by the
units declared beneficiary, in order to substantiate the number of months spent by
correspond to the the seconded staff on the relevant action, taking into consideration
actual number of the limit of months (Procedure n°2).
months spent by the This test is not a sample. It must be applied to 100% of the amount
seconded staff claimed.
members on the The rates for 2014 through 2017 (i.e. for projects funded from the
Research and respective annual budgets) are:
Innovation activities
(RISE).

All rates above are indicated in EUR per person-month. If the costs
for the seconded staff member are eligible, irrespective of any
underpayments, then the Institutional costs are eligible for the
corresponding number of units. Costs not incurred during the
periods of secondments/research and innovation training activity
(e.g. during maternity / parental leave) are ineligible.

Costs can be:

- paid directly to the seconded staff member in advance or via
different instalments or
- managed centrally by the beneficiary according to the specific
needs of the secondment.

If not in EURO: daily rate of the ECB website or the average

monthly accounting rate over the reporting period, using the
currency converter on the Commission's website. For ease of
implementation the allowances can be calculated using a
conservative exchange rate if a corrective payment is made at the
end of the period.
Art. COST 1 Obtain the calculation of the total number of units claimed by the
6.1 & CALCULATION: The CO beneficiary. The costs reported must be equal to the actual number
6.2 costs claimed for FU of units (person-months) multiplied by the unit costs, taking into
recruited researchers ND consideration that for the living allowance in COFUND the country
and the institutional correction coefficient is NOT applicable. Verify that the appropriate
costs must comply unit costs, as per the Work Programme of the year in which the
with the Grant grant was awarded, were used to calculate the total cost claim.
Agreement. The units Obtain the overall calculation and check the number of units with
declared correspond contractual documentation, payroll records, access rights, lab books
to the actual number or other evidence as made available by the beneficiary, in order to
of months spent by substantiate the number of months spent by the researchers on the
the researchers on relevant action, taking into consideration the limit of months
the research training (Procedure n°2).
activities (COFUND).

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 This test is not a sample. It must be applied to 100% of the amount
claimed. For sampling of COFUND Programmes implemented by
partner organisations, refer to procedure 33.

The rates for 2014 through 2017 (i.e. for projects funded from the
respective annual budgets) are:

* These costs are subject to a co-funding rate of 50%.

** The institutional unit cost for COFUND only encompasses the
management costs of beneficiaries; indirect costs are not covered;
they may be funded through other resources including EU
programmes other than Horizon 2020. Costs for visa-related fees
or tuition fees for the research training and/or PhD programme (e.g.
student registration, access to student services (library, computing,
etc.), teaching, supervision, examination and graduation) can only
be covered by the institutional unit costs.

All rates above are indicated in EUR per person-month. If the costs
for the researcher are eligible, irrespective of any underpayments,
then the Institutional costs are eligible for the corresponding
number of units. Costs not incurred during the periods of research
training activity (e.g. during maternity / parental leave) are
ineligible.
If not in EURO: daily rate of the ECB website or the average
monthly accounting rate over the reporting period, using the
currency converter on the Commission's website. For ease of
implementation the allowances can be calculated using a
conservative exchange rate if a corrective payment is made at the
end of the period.

Art. COST CALCULATION 2 Review the contractual documentation and payroll records which
6.2 ITN indicate the number of months spent by the researchers on the
relevant action.
The support granted to eligible researchers will cover the following
periods for which the fellow worked for the action full time (unless
the REA has approved otherwise):
-for ITN, between 3 months minimum and 36 months maximum.

Person-months linked to shorter contracts will not be eligible.

However, this requirement is linked to the duration of the contract
and not to the actual duration of the training. Thus, if the contract is
set out for a longer duration, but the training is interrupted within
the first three months for reasons not related to the beneficiary
(e.g. the researcher resigns), the costs may still be claimed.

112
Art. COST CALCULATION 2 Review the contractual documentation and payroll records which
6.2 IF indicate the number of months spent by the researchers on the
relevant action.
The support granted to eligible researchers will cover the following
periods for which the fellow worked for the action full time (unless
the REA has approved otherwise):
-for IF European, between 12 months minimum and 24 months
maximum.
-for IF Global, between 24 months minimum and 36 months
maximum.
Art. COST CALCULATION 2 Review the contractual documentation and payment transactions
6.2 RI which indicate the number of months spent by the seconded staff
SE members on the relevant action.
The support granted to eligible seconded staff will cover the
following periods for which the fellow worked for the action full
time:
-for RISE, between 1 month minimum and 12 months maximum.

Art. COST CALCULATION 2 Review the contractual documentation and payroll records which
6.2 CO indicate the number of months spent by the researchers on the
FU relevant action.
ND The support granted to eligible researchers will cover the following
periods for which the fellow worked for the action full time (unless
the REA has approved otherwise):
-for COFUND, minimum 3 months.
Art. COST CALCULATION 3 The rates quoted are the unit costs, however there is a minimum
15.1. CO total remuneration cost which must be respected (as per the GA
1.(d) FU and Work Programmes 2014-2015 and 2016-2017). The amount is
ND 2.597 EUR per month for EARLY-STAGE researchers (ESR) and
3.675 EUR per month for EXPERIENCED Researchers (ER).
i.e.: For ESR, the contribution to the fellow will be (3.710 / 2) for the
EC and the total financed by the counterpart should be at least 742
EUR in order to reach the 2.597 EUR minimum.
For researchers recruited under a fixed-amount-fellowship
agreement: the total costs for each fixed-amount fellowship are
equal to or higher than 1.298,50 EUR (for ESR) and 1.837,50 EUR
(for ER).
The difference between an ESR and an ER is detailed here below,
see procedure 11.
Use the payroll records requested under procedure 1 and the
employment contracts/fellowship agreements of the researchers,
CVs and representations regarding ESR and ER categorisation to
determine the eligibility and to compare the total remuneration
amounts per month to the relevant minimums.

Art. COST CALCULATION 4 The beneficiary may have also committed to provide additional
15.1. CO allowances to the researchers or to top up the minimum salary rate.
1. FU This will be clearly stated in Annex 1, which must be checked by the
ND controller.
Compare the total salary amounts per month to the relevant
minimums, plus top-ups.

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 Art. COST CALCULATION 5 Costs declared under another EU or Euratom grant (including grants
6.3(b ITN awarded by a Member State and financed by the EU or Euratom
) budget and grants awarded by bodies other than the Agency for the
purpose of implementing the EU or Euratom budget) in particular,
indirect costs, are ineligible if the beneficiary is already receiving an
operating grant financed by the EU or Euratom budget in the same
period, unless it can demonstrate that the operating grant does not
cover any costs of the action.

Identify via representations from the Beneficiary and Commission

whether the Beneficiary is receiving an operating (not action) grant.

The costs declared shall be as follows:

• for management and indirect costs: EUR 1 200 per person-
month. However, for beneficiaries that already receive an
EU/Euratom operating grant in the same period: only management
costs, i.e. EUR 600 — unless they can demonstrate that the
operating grant does not cover any costs of the action.

Art. COST CALCULATION 5 Costs declared under another EU or Euratom grant (including grants
6.3(b IF awarded by a Member State and financed by the EU or Euratom
) budget and grants awarded by bodies other than the Agency for the
purpose of implementing the EU or Euratom budget) in particular,
indirect costs, are ineligible if the beneficiary is already receiving an
operating grant financed by the EU or Euratom budget in the same
period, unless it can demonstrate that the operating grant does not
cover any costs of the action.

Identify via representations from the Beneficiary and Commission

whether the Beneficiary is receiving an operating (not action) grant.

The costs declared shall be as follows:

• for management and indirect costs: EUR 650 per person-
month. However, for beneficiaries that already receive an
EU/Euratom operating grant in the same period: only management
costs, i.e. EUR 325 — unless they can demonstrate that the
operating grant does not cover any costs of the action.

Art. COST CALCULATION 5 Costs declared under another EU or Euratom grant (including grants
6.3(b RI awarded by a Member State and financed by the EU or Euratom
) SE budget and grants awarded by bodies other than the Agency for the
purpose of implementing the EU or Euratom budget) in particular,
indirect costs, are ineligible if the beneficiary is already receiving an
operating grant financed by the EU or Euratom budget in the same
period, unless it can demonstrate that the operating grant does not
cover any costs of the action.

Identify via representations from the Beneficiary and Commission

whether the Beneficiary is receiving an operating (not action) grant.

The costs declared shall be as follows:

• for management and indirect costs: EUR 700 per person-
month. However, for beneficiaries that already receive an
EU/Euratom operating grant in the same period: only management
costs, i.e. EUR 350 — unless they can demonstrate that the
operating grant does not cover any costs of the action.

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 COST CALCULATION 5 Identify via representations from the Beneficiary and Commission
Art. CO whether the Beneficiary is receiving an operating (not action) grant.
6. FU
3(b) ND Ineligible costs are costs declared under another EU or Euratom
grant (including grants awarded by a Member State and financed by
the EU or Euratom budget and grants awarded by bodies other than
the Agency for the purpose of implementing the EU or Euratom
budget).

Art. DOCUMENTATION: 6 Verify that an employment contract/equivalent direct contract (with

6.2. The costs reported ITN equivalent benefits, including social security coverage) or, if
A(b) must be supported by otherwise not possible under national law, a fixed amount
appropriate fellowship written agreement with minimum social security
supporting coverage, is available and signed by the researcher.
documents
evidencing the In case of a fixed amount fellowship the living allowance will be
effective attendance reduced by 50%.
of the fellow.
Check that the contract matches the relevant dates and conditions
and has been signed.

Art. DOCUMENTATION: 6 Verify that an employment contract/equivalent direct contract (with

6.2. The costs reported IF equivalent benefits, including social security coverage) or, if
A(b) must be supported by otherwise not possible under national law, a fixed amount
appropriate fellowship written agreement with minimum social security
supporting coverage, is available and signed by the researcher.
documents
evidencing the In case of a fixed amount fellowship the living allowance will be
effective attendance reduced by 50%.
of the fellow.
Check that the contract matches the relevant dates and conditions
and has been signed.
Art. DOCUMENTATION: 6 The controller must identify that the formal link between the staff
6.2.A The costs reported RI member and the sending organisation provides the sending
must be supported by SE organisation with the legal means to supervise and instruct the
appropriate seconded staff member according to GA obligations.
supporting
documents
evidencing the formal
link between the
sending organisation
and the seconded
staff member.
Art. DOCUMENTATION: 6 Verify that an employment contract/equivalent direct contract (with
15.1. The costs reported CO equivalent benefits, including social security coverage) or, if
1 must be supported by FU otherwise not possible under national law, a fixed amount
appropriate ND fellowship written agreement with minimum social security
supporting coverage, is available and signed by the researcher.
documents
evidencing the In case of a fixed amount fellowship the living allowance will be
effective attendance reduced by 50%.
of the fellow.
Check that the contract matches the relevant dates and conditions
and has been signed.

115
 Art. WORKING 7 For calls launched on the basis of the work programme(s) in
6.2.A COMMITTMENT ITN force before 25 July 2016.
(b) & Check, based on all kind of evidence that the researcher worked
32.1 exclusively and full-time (or part-time, if agreed with REA
otherwise) for the project within the beneficiary's premises, the
premises of a partner organisation during a secondment, (for
example lab book, attendance list, conference abstract, library
records, travel expenses, etc.). Check e.g. the CV, time-sheets if
available, reports to supervisor, meeting minutes, e-mail exchanges,
etc. and other open sources (internet) whether the researcher
showed that s/he worked on other activities than the project.
Identify if there are any periods where no evidence can be provided
for participation in the project while working for the entity.
For stays in another entity (e.g. in EID or EJD) or secondments (e.g.
in ETN) during the period as foreseen in Annex I will have to be
properly documented (e.g. copy of travel/accommodation
documents, report to supervisor, time-sheets if available, etc.).

For calls launched on the basis of the work programme(s) in

force on or after 25 July 2016.
Check, based on all kind of evidence that the researcher worked
exclusively and full-time (or part-time, if agreed with REA
otherwise) for the project within the beneficiary's premises, the
premises of a partner organisation during a secondment, or the
premises of an entity with a capital or legal link to the beneficiary
mentioned in Annex I to the GA (for example lab book, attendance
list, conference abstract, library records, travel expenses, etc.).
Check e.g. the CV, time-sheets if available, reports to supervisor,
meeting minutes, e-mail exchanges, etc. and other open sources
(internet) whether the researcher showed that s/he worked on other
activities than the project.
Identify if there are any periods where no evidence can be provided
for participation in the project while working for the entity.

If the population is more than 25 items, do a random selection

sample covering 75% of the contribution.

116
 Art. WORKING 7 For calls launched on the basis of the work programme(s) in
6.2.A COMMITTMENT IF force before 25 July 2016.
(b) & Check, based on all kind of evidence that the researcher worked
32.1 exclusively and full-time (or part-time, if agreed with REA
otherwise) for the project within the beneficiary's premises, the
premises of a partner organisation during a secondment, (for
example lab book, attendance list, conference abstract, library
records, travel expenses, etc.). Check e.g. the CV, time-sheets if
available, reports to supervisor, meeting minutes, e-mail exchanges,
etc. and other open sources (internet) whether the researcher
showed that s/he worked on other activities than the project.
Identify if there are any periods where no evidence can be provided
for participation in the project while working for the entity.
For stays in another entity or secondments during the period as
foreseen in Annex I will have to be properly documented (e.g. copy
of travel/accommodation documents, report to supervisor, time-
sheets if available, etc.).

For calls launched on the basis of the work programme(s) in

force on or after 25 July 2016.
Check, based on all kind of evidence that the researcher worked
exclusively and full-time (or part-time, if agreed with REA
otherwise) for the project within the beneficiary's premises, the
premises of a partner organisation during a secondment, or the
premises of an entity with a capital or legal link to the beneficiary
mentioned in Annex I to the GA (for example lab book, attendance
list, conference abstract, library records, travel expenses, etc.).
Check e.g. the CV, time-sheets if available, reports to supervisor,
meeting minutes, e-mail exchanges, etc. and other open sources
(internet) whether the researcher showed that s/he worked on other
activities than the project.
Identify if there are any periods where no evidence can be provided
for participation in the project while working for the entity.
If the population is more than 25 items, do a random selection
sample covering 75% of the contribution.

117
 Art. WORKING 7 For calls launched on the basis of the work programme(s) in
6.2.A COMMITTMENT RI force before 25 July 2016.
(b) & SE Check, based on all kind of evidence that the seconded staff
32.1 member worked exclusively and full-time for the project within the
beneficiaries' premises or the premises of partner organisations
during a secondment, (for example lab book, attendance list,
conference abstract, library records, travel expenses, etc.). Check
e.g. the CV, time-sheets if available, meeting minutes, e-mail
exchanges, etc. and other open sources (internet) whether the
seconded staff member showed that s/he worked on other activities
than the project during his/her secondment.
Identify if there are any periods where no evidence can be provided
for participation in the project while working for the entity.

For calls launched on the basis of the work programme(s) in

force on or after 25 July 2016.
Check, based on all kind of evidence that the seconded staff
member worked exclusively and full-time for the project within the
beneficiaries' premises, the premises of partner organisations, or
the premises of an entity with a capital or legal link to the
beneficiaries/partner organisations mentioned in Annex I to the GA
(for example lab book, attendance list, conference abstract, library
records, travel expenses, etc.) during a secondment. Check e.g. the
CV, time-sheets if available, meeting minutes, e-mail exchanges,
etc. and other open sources (internet) whether the seconded staff
member showed that s/he worked on other activities than the
project during his/her secondment.
Identify if there are any periods where no evidence can be provided
for participation in the project while working for the entity.
If the population is more than 25 items, do a random selection
sample covering 75% of the contribution.

118
 Art. WORKING 7 For calls launched on the basis of the work programme(s) in
15.1. COMMITTMENT CO force before 25 July 2016.
2 FU Check, based on all kind of evidence that the researcher worked
ND exclusively and full-time (or part-time, if agreed with REA
otherwise) for the project within the beneficiary's premises, the
premises of a partner organisation during a secondment, (for
example lab book, attendance list, conference abstract, library
records, travel expenses, etc.). Check e.g. the CV, time-sheets if
available, reports to supervisor, meeting minutes, e-mail exchanges,
etc. and other open sources (internet) whether the researcher
showed that s/he worked on other activities than the project.
Identify if there are any periods where no evidence can be provided
for participation in the project while working for the entity.
For stays in another entity or secondments during the period as
foreseen in Annex I will have to be properly documented (e.g. copy
of travel/accommodation documents, report to supervisor, time-
sheets if available, etc.).

For calls launched on the basis of the work programme(s) in

force on or after 25 July 2016.
Check, based on all kind of evidence that the researcher worked
exclusively and full-time (or part-time, if agreed with REA
otherwise) for the project within the beneficiary's premises, the
premises of a partner organisation during a secondment (for
example lab book, attendance list, conference abstract, library
records, travel expenses, etc.). Check e.g. the CV, time-sheets if
available, reports to supervisor, meeting minutes, e-mail exchanges,
etc. and other open sources (internet) whether the researcher
showed that s/he worked on other activities than the project.
Identify if there are any periods where no evidence can be provided
for participation in the project while working for the entity.
If the population is more than 25 items, do a random selection
sample covering 75% of the contribution.
Art. DOCUMENTATION : 8 Verify that the Beneficiary did not receive any contribution from
6.3.( DOUBLE FUNDING ITN another EU funding programme for any of the cost items funded
b) under the MSCA grant.
Obtain management representations and documentation provided
by the Beneficiary in relation to other EU funding programmes (i.e.
list of projects granted by the EU to the Beneficiary, etc.). Ensure
that management representations are not contradictory with other
evidence obtained in the assignment.

Art. DOCUMENTATION : 8 Verify that the Beneficiary did not receive any contribution from
6.3.( DOUBLE FUNDING IF another EU funding programme for any of the cost items funded
b) under the MSCA grant.
Obtain management representations and documentation provided
by the Beneficiary in relation to other EU funding programmes (i.e.
list of projects granted by the EU to the Beneficiary, etc.). Ensure
that management representations are not contradictory with other
evidence obtained in the assignment.
Art. DOCUMENTATION: 8 Verify that the Beneficiary did not receive any contribution from
6.3(b DOUBLE FUNDING RI another EU funding programme for any of the cost items funded
) SE under the MSCA grant.
Obtain management representations and documentation provided
by the Beneficiary in relation to other EU funding programmes (i.e.
list of projects granted by the EU to the Beneficiary, etc.). Ensure
that management representations are not contradictory with other
evidence obtained in the assignment.

119
 Art. DOCUMENTATION: 8 For COFUND, matching funds (received by the beneficiary and not
15.1. DOUBLE FUNDING CO the researcher) can come from EU funds other than Horizon 2020
1. FU funds.
Art. ND Obtain management representations and documentation provided
6.3(b by the Beneficiary in relation to other EU funding programmes (i.e.
) list of projects granted by the EU to the Beneficiary, etc.). Ensure
that management representations are not contradictory with other
evidence obtained in the assignment.

Art. EFFECTIVE 9 Review the following supporting documents (contractual

6.2 PAYMENT: The costs ITN documentation, payroll records) in order to reconcile the amount
.A claimed must be claimed in the Cost Claim(s) and the payroll, proceeding as follows:
(c) incurred during the detailed breakdown of annual personnel costs for the months
duration of the claimed from the payroll (total cost of the researcher including
project. The taxes and contribution to social security insurances), indicating per
researchers must be person the category, the monthly rate, the number of months
remunerated on a charged compared to the cost claimed.
monthly basis The personnel cost should be at least equal to the cost claimed.
according to the Total remuneration costs should at least cover the total living,
Grant Agreement. mobility and family (if applicable) allowance or, if applicable, fixed-
amount fellowship costs + total mobility allowance + family (if
applicable) allowance.
This test is not a sample. It must be applied to 100% of the
amount claimed.

Art. EFFECTIVE 9 Review the following supporting documents (contractual

6.2 PAYMENT: The costs IF documentation, payroll records) in order to reconcile the amount
.A claimed must be claimed in the Cost Claim(s) and the payroll, proceeding as follows:
(c) incurred during the detailed breakdown of annual personnel costs for the months
duration of the claimed from the payroll (total cost of the researcher including
project. The taxes and contribution to social security insurances), indicating per
researchers must be person the category, the monthly rate, the number of months
remunerated on a charged compared to the cost claimed.
monthly basis The personnel cost should be at least equal to the cost claimed.
according to the Total remuneration costs should at least cover the total living,
Grant Agreement. mobility and family (if applicable) allowance or, if applicable, fixed-
amount fellowship costs + total mobility allowance + family (if
applicable) allowance.
This test is not a sample. It must be applied to 100% of the
amount claimed.
Art. EFFECTIVE 9 Review the following supporting documents (e.g. contractual
6.2 PAYMENT: The unit RI documentation, payment transactions).
.A costs claimed must SE This test is not a sample. It must be applied to 100% of the
refer to secondments amount claimed.
incurred during the
duration of the
project. The seconded
staff members must
receive the
corresponding
amount on a monthly
basis according to the
Grant Agreement.

120
Art. EFFECTIVE 9 Review the following supporting documents (contractual
6.2 PAYMENT: The costs CO documentation, payroll records) in order to reconcile the amount
.A claimed must be FU claimed in the Cost Claim(s) and the payroll, proceeding as follows:
incurred during the ND detailed breakdown of annual personnel costs for the months
An duration of the claimed from the payroll (total cost of the researcher including
d project. The taxes and contribution to social security insurances), indicating per
researchers must be person the category, the monthly rate, the number of months
.Art remunerated on a charged compared to the cost claimed.
. monthly basis The personnel cost should be at least equal to the cost claimed.
15. according to the This test is not a sample. It must be applied to 100% of the
1.1 Grant Agreement. amount claimed. For sampling of COFUND Programmes
(d) implemented by partner organisations, refer to procedure 33.
The minimum requirements in Art. 15.1.1(d) and Work Programmes
2014-2015 and 2016-2017 are as follows:
- For DPs: for researchers recruited under an employment
contract (or other direct contract with equivalent benefits,
including social security): the total remuneration costs
(salaries, social security contributions, taxes and other
costs included in the remuneration) for each researcher per
month are equal to or higher than EUR 2 597. For
researchers recruited under a fixed-amount-fellowship
agreement: the total costs of each fixed-amount
fellowship per month are equal to or higher than EUR 1
298,50;
- For FPs: for researchers recruited under an employment
contract (or other direct contract with equivalent benefits,
including social security): the total remuneration costs
(salaries, social security contributions, taxes and other
costs included in the remuneration) for each researcher per
month are equal to or higher than EUR 3 675;. For
researchers recruited under a fixed-amount-fellowship
agreement: the total costs of each fixed-amount
fellowship per month are equal to or higher than EUR 1
837,50.

Art. EFFECTIVE PAYMENT 10 Obtain bank statements supporting the payment to the researcher.
6.2.A ITN In case of batch payment, the total amount has to be reconciled
(c) with the payments made by the Beneficiary exclusively; obtain the
breakdown per individual payment.
Verify that the bank statements substantiate the payment of the
net remuneration (amount that remains after withholdings
deducted from employee's gross pay).
Ensure net pay is not contradictory with other employment costs
already checked.
This test is not a sample. It must be applied to 100% of the
amount claimed.
Art. EFFECTIVE PAYMENT 10 Obtain bank statements supporting the payment to the researcher.
6.2.A IF In case of batch payment, the total amount has to be reconciled
(c) with the payments made by the Beneficiary exclusively; obtain the
breakdown per individual payment.
Verify that the bank statements substantiate the payment of the
net remuneration (amount that remains after withholdings
deducted from employee's gross pay).
Ensure net pay is not contradictory with other employment costs
already checked.
This test is not a sample. It must be applied to 100% of the
amount claimed.

121
 Art. EFFECTIVE PAYMENT 10 Verify that the unit costs under Category A is used in full to cover
6.2.A RI the travel, subsistence and accommodation costs of the seconded
SE staff member (e.g. direct payments to staff members, invoices for
hotels, travel tickets, etc.).

Art. EFFECTIVE PAYMENT 10 Obtain bank statements supporting the payment to the researcher.
6.2.A CO In case of batch payment, the total amount has to be reconciled
Art. FU with the payments made by the Beneficiary exclusively; obtain the
15.1. ND breakdown per individual payment.
1. (d) Verify that the bank statements substantiate the payment of the
net remuneration (amount that remains after withholdings
deducted from employee's gross pay).
Ensure net pay is not contradictory with other employment costs
already checked.
This test is not a sample. It must be applied to 100% of the
amount claimed. For sampling of COFUND Programmes
implemented by partner organisations, refer to procedure 33.
Art. ELIGIBILITY: it must 11 For calls launched on the basis of the work programme
6.2.A be verified that the ITN 2014-15.
researchers were Early-stage researchers (ESR) shall at the time of recruitment by
eligible for the the host organisation, be in the first four years (full-time equivalent
project. research experience) of their research careers and have not been
awarded a doctoral degree.

For calls launched on the basis of the work programme(s)

2016-17 in force before 25 July 2016.
Early-stage researchers (ESR): at the time of recruitment,
researchers shall be in the first four years (full time equivalent
research experience) of their research careers and not been
awarded a doctoral degree.
Full-time equivalent research experience: is measured from the
date when a researcher obtained the degree entitling him/her to
embark on a doctorate (either in the country in which the degree
was obtained or in the country in which the researcher is recruited
or seconded) - even if a doctorate was never started or envisaged.
Obtain CVs, copies of the qualifications of researchers and all kind
of private/public information (available on internet: i.e. LinkedIn,
etc.) made available by the beneficiary.
Verify that the documents do not indicate longer or shorter periods
of full time research experience, or that the researcher has or not a
doctorate.

For calls launched on the basis of the work programme(s)

2016-17 in force after 25 July 2016.
Early-stage researchers (ESR): at the date of recruitment,
researchers shall be in the first four years (full-time equivalent
research experience) of their research careers and have not been
awarded a doctoral degree.
Full-time equivalent research experience: is measured from the
date when a researcher obtained the degree entitling him/her to
embark on a doctorate (either in the country in which the degree
was obtained or in the country in which the researcher is recruited
or seconded) - even if a doctorate was never started or envisaged.
Obtain CVs, copies of the qualifications of researchers and all kind
of private/public information (available on internet: i.e. LinkedIn,
etc.) made available by the beneficiary.

122
 Verify that the documents do not indicate longer or shorter periods
of full time research experience, or that the researcher has or not a
doctorate.
For ESR, verify that the ESR would be allowed to embark on a
doctorate with the title he/she was holding at the time of
recruitment (in most countries at least Master's degree but in some
also BA degree).
Art. ELIGIBILITY: it must 11 For calls launched on the basis of the work programme
32.1 be verified that the IF 2014-15.
& researchers were Experienced researchers (ER) shall, at the time of the relevant
Work eligible for the project deadline for submission of proposals by the host organisation, be in
Progr possession of a doctoral degree or have at least four years of full-
amm time equivalent research experience.
e
For calls launched on the basis of the work programme(s)
2016-17 in force before 25 July 2016.
Experienced Researcher (ER): shall at the time of the call deadline
by the host organisation, be in possession of a doctoral degree or
have at least four years of full-time equivalent research experience.
Full-time equivalent research experience: is measured from the
date when a researcher obtained the degree which would formally
entitle him or her to embark on a doctorate, either in the country in
which the degree was obtained or in the country in which the
researcher is recruited or seconded, irrespective of whether or not a
doctorate is or was envisaged.
Obtain CVs, copies of the qualifications of researchers and all kind
of private/public information (available on internet: i.e. LinkedIn,
etc.) made available by the beneficiary.
Verify that the documents do not indicate longer or shorter periods
of full time research experience, or that the researcher has or not a
doctorate.
Control on long-term residence for IF - Global Fellowship and IF –
Reintegration Panel:
The controllers must check that the 5-year condition for long-term
residents is fulfilled for non-nationals of EU Member States or
H2020 associated countries.

For calls launched on the basis of the work programme(s)

2016-17 in force after 25 July 2016.
Experienced Researchers (ER): shall at the date of the call deadline
be in possession of a doctoral degree (A medical doctor degree will
not be accepted by itself as equivalent to a doctoral degree. To be
considered as experienced researchers, medical doctors need to
provide the certificates of a doctoral degree or information on their
research experience) or have at least four years of full-time
equivalent research experience.
Full-time equivalent research experience: is measured from the
date when a researcher obtained the degree which would formally
entitle him or her to embark on a doctorate, either in the country in
which the degree was obtained or in the country in which the
researcher is recruited or seconded, irrespective of whether or not a
doctorate is or was envisaged.
Obtain CVs, copies of the qualifications of researchers and all kind
of private/public information (available on internet: i.e. LinkedIn,
etc.) made available by the beneficiary.
Verify that the documents do not indicate longer or shorter periods
of full time research experience, or that the researcher has or not a
doctorate.

123
 Control on long-term residence for IF - Global Fellowship and IF –
Reintegration Panel:
The controllers must check that the 5-year condition for long-term
residents is fulfilled for non-nationals of EU Member States or
associated countries. Long-term residence means a period of full-
time research activity in the EU or Horizon 2020 associated
countries of at least 5 consecutive years.
Art. ELIGIBILITY of 11 For calls launched on the basis of the work programme
6.2.A Early-stage RI 2014-15.
(b) Researchers and SE Early-stage researchers (ESR) shall at the time of secondment by
Experienced the host organisation, be in the first four years (full-time equivalent
Researchers: it research experience) of their research careers and have not been
must be verified that awarded a doctoral degree.
these seconded staff Experienced researchers (ER) shall, at the time of the relevant
members were deadline for secondment by the host organisation, be in possession
eligible for the of a doctoral degree or have at least four years of full-time
project. equivalent research experience.
For calls launched on the basis of the work programme(s)
2016-17 in force before and after 25 July 2016.
Early-stage researchers (ESR): at the time of secondment by the
host organisation, researchers shall be in the first four years (full
time equivalent research experience) of their research careers and
not been awarded a doctoral degree.
Experienced Researcher (ER): shall at the time of the relevant
deadline for secondment by the host organisation, be in possession
of a doctoral degree or have at least four years of full-time
equivalent research experience.
Full-time equivalent research experience: is measured from the
date when a researcher obtained the degree entitling him/her to
embark on a doctorate (either in the country in which the degree
was obtained or in the country in which the researcher is recruited
or seconded) - even if a doctorate was never started or envisaged.
Obtain CVs, copies of the qualifications of researchers and all kind
of private/public information (available on internet: i.e. LinkedIn,
etc.) made available by the beneficiary.
Verify that the documents do not indicate longer or shorter periods
of full time research experience, or that the researcher has or not a
doctorate.
For ESR, verify that the ESR would be allowed to embark on a
doctorate with the title he/she was holding at the time of
recruitment (in most countries at least Master's degree but in some
also BA degree).
Art. ELIGIBILITY: it must 11 For calls launched on the basis of the work programme
15.1 be verified that the CO 2014-15.
researchers were FU Early-stage researchers (ESR) shall at the time of recruitment by
eligible for the ND the host organisation, be in the first four years (full-time equivalent
project. research experience) of their research careers and have not been
awarded a doctoral degree.
Experienced researchers (ER) shall, at the time of the relevant
deadline for recruitment by the host organisation, be in possession
of a doctoral degree or have at least four years of full-time
equivalent research experience.

124
For calls launched on the basis of the work programme(s)
2016-17 in force before 25 July 2016.
Early-stage researchers (ESR): at the time of recruitment (COFUND-
Doctoral Programmes) by the host organisation, researchers shall
be in the first four years (full time equivalent research experience)
of their research careers and not been awarded a doctoral degree.
Experienced Researcher (ER): shall at the time recruitment (
COFUND-Fellowship Programmes) by the host organisation, be in
possession of a doctoral degree or have at least four years of full-
time equivalent research experience.
Full-time equivalent research experience: is measured from the
date when a researcher obtained the degree entitling him/her to
embark on a doctorate (either in the country in which the degree
was obtained or in the country in which the researcher is recruited
or seconded) - even if a doctorate was never started or envisaged.
Obtain CVs, copies of the qualifications of researchers and all kind
of private/public information (available on internet: i.e. LinkedIn,
etc.) made available by the beneficiary.
Verify that the documents do not indicate longer or shorter periods
of full time research experience, or that the researcher has or not a
doctorate.

For calls launched on the basis of the work programme(s)

2016-17 in force after 25 July 2016.
Early-stage researchers (ESR): at the date of recruitment or the
deadline of the co-funded programme's call (COFUND DP) ,
researchers shall be in the first four years (full-time equivalent
research experience) of their research careers and have not been
awarded a doctoral degree.
Experienced Researchers (ER): at the date of recruitment or the
deadline of the co-funded programme's call (COFUND-FP) be in
possession of a doctoral degree (A medical doctor degree will not
be accepted by itself as equivalent to a doctoral degree. To be
considered as experienced researchers, medical doctors need to
provide the certificates of a doctoral degree or information on their
research experience) or have at least four years of full-time
equivalent research experience.
Full-time equivalent research experience: is measured from the
date when a researcher obtained the degree which would formally
entitle him or her to embark on a doctorate, either in the country in
which the degree was obtained or in the country in which the
researcher is recruited or seconded, irrespective of whether or not a
doctorate is or was envisaged.
Obtain CVs, copies of the qualifications of researchers and all kind
of private/public information (available on internet: i.e. LinkedIn,
etc.) made available by the beneficiary.
Verify that the documents do not indicate longer or shorter periods
of full time research experience, or that the researcher has or not a
doctorate.
For ESR, verify that the ESR would be allowed to embark on a
doctorate with the title he/she was holding at the time of
recruitment (in most countries at least Master's degree but in some
also BA degree).

125
 Art. ELIGIBILITY 12 Inter-sectorial mobility: Applicable only after final period: For
6.2.A ITN ITN-EID, each researcher shall spend at least 50% of the months
(a) working on the action in the non-academic sector. Note that at the
level of the interim report, the EID project may deviate from the
50/50% principle if more academic work is planned in the 1st period.
For calls launched on the basis of Work Programme(s) 2014-
2015:
Researchers in EID shall spend at least 50% of their time in the
non-academic sector.

For call launched on the basis of Work Programme 2016-

2017 in force as of 13 October 2015
For ITN EID, researchers must spend at least 50% of their time in
the non-academic sector. The inter-sectoral mobility has to be
between beneficiaries located in different countries.

For call launched on the basis of Work Programme(s) 2016-

2017 in force after 9 March 2016
For ITN EID, researchers must spend at least 50% of their time in
the non-academic sector. This inter-sectoral mobility has to be
between participating organisations located in different countries.

Verify for each researcher that he/she spent at least 50% of the
months in the non-academic sector by checking:
1) the beneficiary/partner organisation where the researcher
worked and determine if they fall within the academic or the non-
academic sector and
2) that at least 50% of units declared correspond to months spent
in the non-academic sector.
Art. ELIGIBILITY 13 For calls launched on the basis of the work programme
6.2.A ITN 2014-15.
At the time of the relevant deadline for recruitment by the host
organisation, researchers shall not have resided or carried out their
main activity (work, studies, etc.) in the country of their host
organisation for more than 12 months in the 3 years immediately
prior to the reference date. Compulsory national service and/or
short stays such as holidays are not taken into account. As far as
international European interest organisations or international
organisations are concerned, this rule does not apply to the hosting
of eligible researchers. However the appointed researcher shall not
have spent more than 12 months in the 3 years immediately prior
to the reference date for ITN, in the same appointing organisation.

For calls launched on the basis of the work programme(s)

2016-17 in force before 25 July 2016.
Researchers may not have resided or carried out their main activity
(work, studies, etc.) in the country of their host organisation for
more than 12 months in the 3 years immediately before the
reference date: date of recruitment in ITN. Compulsory national
service and/or short stays such as holidays are not taken into
account.
For 'international European interest organisations' or 'international
organisations', the researchers may not have spent more than 12
months in the 3 years immediately before the call
deadline/recruitment, in the same appointing organisation.

126
 For calls launched on the basis of the work programme(s)
2016-17 in force after 25 July 2016.
Mobility rule: At the time of the relevant deadline for recruitment by
the host organisation, researchers shall not have resided or carried
out their main activity (work, studies, ...) in the country of their host
organisation for more than 12 months in the 3 years immediately
prior to the reference date. Compulsory national service, short
stays such as holidays and time spent as part of a procedure for
obtaining refugee status under the Geneva Convention (1951
Refugee Convention and the 1967 Protocol) are not taken into
account. As far as international European interest organisations or
international organisations are concerned, this rule does not apply
to the hosting of eligible researchers. However the appointed
researcher shall not have spent more than 12 months in the 3
years immediately prior to the reference date for ITN, in the same
appointing organisation.
For researchers with refugee status, as defined by the Geneva
Convention (1951 Refugee Convention and the 1967 Protocol):
- The time needed to process the application for refugee status (i.e.
before refugee status is conferred) will not be counted as 'period of
residence/activity in the country of the beneficiary'.
Obtain management representations and 3rd party documentation
provided by the Beneficiary (i.e. ID card or a residence permit,
registration documents, lease agreement, bills, etc., - non-
exhaustive list) to verify that the aforementioned rules have been
observed.
Work ELIGIBILITY 13 For calls launched on the basis of the work programme
Progr IF 2014-15.
amm At the time of the relevant deadline for submission of proposals,
e researchers shall not have resided or carried out their main activity
(work, studies, etc.) in the country of their host organisation for
more than 12 months in the 3 years immediately prior to the
reference date. Compulsory national service and/or short stays such
as holidays are not taken into account. As far as international
European interest organisations or international organisations are
concerned, this rule does not apply to the hosting of eligible
researchers. However the appointed researcher shall not have spent
more than 12 months in the 3 years immediately prior to the
reference date in the same appointing organisation.
In the Career Restart Panel and the Reintegration Panel in IF,
researchers shall not have resided or carried out their main activity
in the country of their host organisation for more than 3 years in
the 5 years immediately prior to the relevant deadline for
submission of proposals.

For calls launched on the basis of the work programme(s)

2016-17 in force before 25 July 2016.
Researchers may not have resided or carried out their main activity
(work, studies, etc.) in the country of their host organisation for
more than 12 months in the 3 years immediately before the
reference date: the call deadline for IF. Compulsory national service
and/or short stays such as holidays are not taken into account.
For 'international European interest organisations' or 'international
organisations', the researchers may not have spent more than 12
months in the 3 years immediately before the call
deadline/recruitment, in the same appointing organisation.

127
 For IF Society and Enterprise Panel, Career Restart Panel and
Reintegration Panel, researchers may not have resided or carried
out their main activity in the country of their host organisation for
more than 3 years in the 5 years immediately before the reference
date.

For calls launched on the basis of the work programme(s)

2016-17 in force after 25 July 2016.
Mobility rules: At the time of the relevant deadline for submission
of proposals, researchers shall not have resided or carried out their
main activity (work, studies, ...) in the country of their host
organisation for more than 12 months in the 3 years immediately
prior to the reference date. Compulsory national service, short
stays such as holidays and time spent as part of a procedure for
obtaining refugee status under the Geneva Convention (1951
Refugee Convention and the 1967 Protocol) are not taken into
account. As far as international European interest organisations or
international organisations are concerned, this rule does not apply
to the hosting of eligible researchers. However the appointed
researcher shall not have spent more than 12 months in the 3
years immediately prior to the reference date in the same
appointing organisation.
In the Career Restart Panel, the Reintegration Panel as well as the
Society and Enterprise Panel in IF, researchers shall not have
resided or carried out their main activity in the country of their host
organisation for more than 3 years in the 5 years immediately prior
to the relevant deadline for submission of proposals.
For researchers with refugee status, as defined by the Geneva
Convention (1951 Refugee Convention and the 1967 Protocol):
- The time needed to process the application for refugee status (i.e.
before refugee status is conferred) will not be counted as 'period of
residence/activity in the country of the beneficiary'.
- Concerning only the Reintegration Panel of the European
Fellowships or any Global Fellowship, any time spent obtaining
refugee status in a Member State or Associated Country will be
deemed as counting towards the minimum 5-year period of full-
time research activity to acquire long-term resident status.
Obtain management representations and 3rd party documentation
provided by the Beneficiary (i.e. ID card or a residence permit,
registration documents, lease agreement, bills, etc., - non-
exhaustive list) to verify that the aforementioned rules have been
observed.
Art. ELIGIBILITY 13 For calls launched on the basis of the work programme
15.1. CO 2014-15.
1. FU At the time of the relevant deadline for recruitment by the host
ND organisation (COFUND Doctoral Programmes and COFUND
Fellowship Programmes), researchers shall not have resided or
carried out their main activity (work, studies, etc.) in the country of
their host organisation for more than 12 months in the 3 years
immediately prior to the reference date. Compulsory national
service and/or short stays such as holidays are not taken into
account. As far as international European interest organisations or
international organisations are concerned, this rule does not apply
to the hosting of eligible researchers. However the appointed
researcher shall not have spent more than 12 months in the 3
years immediately prior to the reference date in the same
appointing organisation.

128
For calls launched on the basis of the work programme(s)
2016-17 in force before 25 July 2016.
Researchers may not have resided or carried out their main activity
(work, studies, etc.) in the country of their host organisation for
more than 12 months in the 3 years immediately before the
reference date: the call deadline (IF), recruitment (COFUND Doctoral
programmes (DP)) or either of these two points in time (COFUND
Fellowship programmes (FP)). Compulsory national service and/or
short stays such as holidays are not taken into account.
For 'international European interest organisations' or 'international
organisations', the researchers may not have spent more than 12
months in the 3 years immediately before the call
deadline/recruitment, in the same appointing organisation.
For COFUND activities equivalent to IF Society and Enterprise
Panel, Career Restart Panel and Reintegration Panel , researchers
may not have resided or carried out their main activity in the
country of their host organisation for more than 3 years in the 5
years immediately before the reference date.

For calls launched on the basis of the work programme(s)

2016-17 in force after 25 July 2016.
Mobility rules: At the time of the relevant deadline for submission
of proposals or recruitment by the host organisation in time,
researchers shall not have resided or carried out their main activity
(work, studies, ...) in the country of their host organisation for more
than 12 months in the 3 years immediately prior to the reference
date. Compulsory national service, short stays such as holidays and
time spent as part of a procedure for obtaining refugee status
under the Geneva Convention (1951 Refugee Convention and the
1967 Protocol) are not taken into account. As far as international
European interest organisations or international organisations are
concerned, this rule does not apply to the hosting of eligible
researchers. However the appointed researcher shall not have spent
more than 12 months in the 3 years immediately prior to the
reference date in the same appointing organisation.
For COFUND activities equivalent to the Career Restart Panel, the
Reintegration Panel as well as the Society and Enterprise Panel in
IF, researchers shall not have resided or carried out their main
activity in the country of their host organisation for more than 3
years in the 5 years immediately prior to the relevant deadline for
submission of proposals.
For researchers with refugee status, as defined by the Geneva
Convention (1951 Refugee Convention and the 1967 Protocol):
- The time needed to process the application for refugee status (i.e.
before refugee status is conferred) will not be counted as 'period of
residence/activity in the country of the beneficiary'.
Obtain management representations and 3rd party documentation
provided by the Beneficiary (i.e. ID card or a residence permit,
registration documents, lease agreement, bills, etc., - non-
exhaustive list) to verify that the aforementioned rules have been
observed.

129
 Art. ELIGIBILITY 14 The mobility rules may deviate from the standard rules but only
15.1. CO if it is explicitly stated in Annex 1 and for already existing
1 FU programmes only. Researchers that are already permanently
ND employed by the entity where the research training activities take
place are not eligible for funding under COFUND.

Obtain management representations and 3rd party documentation

provided by the beneficiary (employment contracts, CVs and all kind
of private/public information) that will confirm the above condition.
Ask Annex 1 and check deviation.
Art ELIGIBILITY 15 The staff members eligible for funded secondments in RISE must
6.2.A RI fulfil the following cumulative conditions:
(b) SE 1. Be actively engaged in or linked to research and/or innovation
activities at the sending organisation for at least 1 month (full-
time equivalent) prior to the first period of secondment.
2. The formal link between the staff member and the sending
organisation provides to the sending organisation the legal
means under national law to supervise and instruct the
seconded staff member according to GA obligations during the
secondment.
3. Support the research and innovation activities of the project.
4. Be one of the following:
- an ‘early stage researcher’ (i.e. in the first four years of his/her
research career and not have a doctoral degree);
- an ‘experienced researcher’ (i.e. in possession of a doctoral degree
or have at least four years of research experience), or
- administrative, managerial or technical staff supporting research
and innovation activities under the action
Obtain management representations and 3rd party documentation
provided by the Beneficiary (i.e. the CV showing the researcher’s
seniority, activity reports, articles) to confirm the above conditions.
Conditions 1 and 4 are set up in article 6.2 Specific conditions for
costs to be eligible.

Art. Obligations towards 16 Charter and Code (Art. 32): the Beneficiary has to take all measures
32.1 recruited ITN to implement the principles set out in the Commission
(a) researchers: the Recommendation on the European Charter for Researchers and the
Beneficiary has to Code of Conduct for the Recruitment of Researchers and ensure
respect the various that the researchers are aware of them.
recruitment and
working conditions Check that the researcher has been informed about the C&C.
(Art. 32)
Art. Obligations towards 16 Charter and Code (Art. 32): the Beneficiary has to take all measures
32.1 recruited IF to implement the principles set out in the Commission
(a) researchers: the Recommendation on the European Charter for Researchers and the
Beneficiary has to Code of Conduct for the Recruitment of Researchers and ensure
respect the various that the researchers are aware of them.
recruitment and
working conditions Check that the researcher has been informed about the C&C.
(Art. 32)

130
Art. Obligations towards 16 Charter and Code (Art. 32): the Beneficiary has to take all measures
32.1 seconded staff RIS to implement the principles set out in the Commission
(a) members: the E Recommendation on the European Charter for Researchers and the
Beneficiary has to Code of Conduct for the Recruitment of Researchers and ensure
respect the various that the seconded staff members are aware of them.
recruitment and
working conditions Check that the seconded staff members have been informed about
(Art. 32) the C&C.
Art. Obligations towards 16 Charter and Code (Art. 15.1.2): the Beneficiary has to take all
15.1 recruited CO measures to implement the principles set out in the Commission
.2 researchers: the FU Recommendation on the European Charter for Researchers and the
Beneficiary has to ND Code of Conduct for the Recruitment of Researchers and ensure
respect the various that the researchers are aware of them.
recruitment and
working conditions Check that the researcher has been informed about the C&C.
(Art. 32)
Art VACANCIES 17 VACANCIES PUBLICATIONS: the publication of the vacancies/calls
32.1 PUBLICATIONS ITN must be advertised internationally, including on the websites
(b) requested by REA.

Obtain a print out of the EURAXESS Jobs Portal registration for the
specific post and any international advertising on the internet to
confirm the above condition.
Art. VACANCIES 17 VACANCIES PUBLICATIONS: the publication of the vacancies/calls
15.1. PUBLICATIONS CO must be advertised internationally, including on the websites
1 FU requested by REA.
ND
Obtain a print out of the EURAXESS Jobs Portal registration for the
specific post and any international advertising on the internet to
confirm the above condition.
Art RECRUITMENT 18 RECRUITMENT PROCEDURE: this procedure must be open,
32.1. PROCEDURE ITN transparent, merit-based, impartial and equitable on the basis of:
(c) 1) their specific skills and the relevance of their research
experience;
2) the impact of the proposed training on the researcher's career;
3) a fair gender balance (by promoting genuine equal access
opportunities between men and women throughout the recruitment
process).

Obtain the vacancies lists and the report of the recruitment

procedure.

Obtain the procedure of the beneficiary and check that it was

carried out with due respect to the above criteria.

131
 Art. RECRUITMENT 18 For DPs: Researchers must be selected following an open,
15.1. PROCEDURE CO transparent, merit-based, impartial and equitable selection
1(c) FU procedure, as described in Annex 1.
and ND Vacancies must be internationally advertised and published
15.1. (including on the web-sites requested by the Agency).
2
For DP (depending on applicable MGA version): 1) ensure gender
balance in the recruited researchers; or 2) ensure a fair gender
representation in the recruited researchers (by promoting genuine
equal access opportunities between men and women throughout
the recruitment process).

For FP: Researchers must be selected following an open,

transparent, merit-based, impartial and equitable selection
procedure, based on international peer review, as described in
Annex 1.
The selection committee(s) must bring together diverse expertise,
have an adequate gender balance and include members from other
countries and with relevant experience to assess the candidates.

Fellowships must be granted via regular calls that are

internationally advertised and published (including on the web-sites
requested by the Agency) and have fixed deadlines or regular cut-
off dates.
There must be no more than 4 deadlines or cut-off dates per year.

Obtain the vacancies lists and the report of the recruitment

procedure.

Obtain the procedure of the beneficiary and check that it was

carried out with due respect to the above criteria.
Art CONFLICT OF 19 CONFLICT OF INTEREST : ensure that no conflict of interest exists in
32.1. INTERESTS ITN or arises from the recruitment procedure (e.g. a self-declaration
(d) from the beneficiary).

Art. CONFLICT OF 19 CONFLICT OF INTEREST: ensure that no conflict of interest exists in

15 INTERESTS CO or arises from the recruitment procedure (e.g. a self-declaration
Art. FU from the beneficiary).
35 ND
Art. WORKING CONDITIONS 20 WORKING CONDITIONS: ensure that the researchers enjoy at the
32.1. ITN place of the implementation at least the same standards and
(e) working conditions as those applicable to local researchers holding
a similar position.

Obtain information and management representations confirming

that the MSCA researchers have equal access to facilities, research
equipment, etc. and are treated in the same way (and are equally
supported) as locally recruited researchers by the beneficiary.

132
 Art. WORKING CONDITIONS 20 WORKING CONDITIONS: ensure that the researchers enjoy at the
32.1. IF place of the implementation at least the same standards and
(b) working conditions as those applicable to local researchers holding
a similar position.

Obtain information and management representations confirming

that the MSCA researchers have equal access to facilities, research
equipment etc. and are treated in the same way (and are equally
supported) as locally recruited researchers by the beneficiary.

Art WORKING CONDITIONS 20 WORKING CONDITIONS: ensure that the seconded staff members
32.1 RI enjoy at the place of the implementation at least the same
(d) SE standards and working conditions as those applicable to local
persons holding a similar position.

Obtain information and management representations confirming

that the working conditions – e.g. access to labs, access to
background and results, etc. – for the seconded staff member are
at least as good as for local staff holding a similar position.

Art. WORKING CONDITIONS 20 WORKING CONDITIONS: ensure that the researchers enjoy at the
15.1. CO place of the implementation at least the same standards and
2 FU working conditions as those applicable to local researchers holding
ND a similar position.

Obtain information and management representations confirming

that the MSCA researchers have equal access to facilities, research
equipment etc.– and are treated in the same way (and are equally
supported) as locally recruited researchers by the
beneficiary/partner organisation.

Art EMPLOYMENT 21 EMPLOYMENT CONTRACT: employment contract, other direct

32.1. CONTRACT CONDITIONS ITN contract or fixed-amount-fellowship agreement specify:
(f) 1) the starting date and duration of the research training activities
under the action
2) the monthly support for the researcher under this Agreement (in
Euro or the currency in which the remuneration is paid).
3) the obligation of the researcher to work exclusively for the
action
4) the obligation of the researcher not to receive for activities
carried out in the frame of the action, other incomes than those
received from the beneficiary (or any other entity referred to in
the annex 1).
5) the obligation of the researcher to inform the beneficiary as
soon as possible of any events or circumstances likely to affect
the Agreement (see art 17)
6) the arrangements related to the intellectual property rights
between the beneficiary and the researcher during
implementation of the action and afterwards
7) the obligation of the researcher to maintain confidentiality (see
Art 36)
8) the obligation of the researcher to ensure the visibility of EU
funding in communications or publications and in applications
for the protection of results (Art 27, 28, 29 and 38)

Obtain the researcher’s employment contract or corresponding

agreement and check that all the points 1) to 8) are specified.

133
 Art EMPLOYMENT 21 EMPLOYMENT CONTRACT: employment contract, other direct
32.1. CONTRACT CONDITIONS IF contract or fixed-amount-fellowship agreement specify:
(c) 1) the name of the supervisor for the research training activities
as indicated in Annex 1
2) the starting date and duration of the research training activities
under the action
3) the monthly support for the researcher under this Agreement (in
Euro or the currency in which the remuneration is paid).
4) the obligation of the researcher to work exclusively for the
action
5) the obligation of the researcher not to receive for activities
carried out in the frame of the action, other incomes than those
received from the beneficiary (or any other entity referred to in
the annex 1).
6) the obligation of the researcher to inform the beneficiary as
soon as possible of any events or circumstances likely to affect
the Agreement (see art 17)
7) the arrangements related to the intellectual property rights
between the beneficiary and the researcher during
implementation of the action and afterwards
8) the obligation of the researcher to maintain confidentiality (see
Art 36)
9) the obligation of the researcher to ensure the visibility of EU
funding in communications or publications and in applications
for the protection of results (Art 27, 28, 29 and 38)
10) For Global Fellowships only: the obligation of the researcher to
carry out a mandatory return period of 12 months at the
premises of the beneficiary;

Obtain the researcher’s employment contract or corresponding

agreement and check that all the points 1) to 10) are specified.
Art INFORMATION TO THE 22 INFORMATION TO THE RESEARCHER: the beneficiary has to inform
32.1. RESEARCHER ITN the researcher on the following aspects:
(h) 1) the description, conditions, location and the timetable for the
implementation of the research training activities under the
action and the name of the supervisor
2) the rights and obligations of the beneficiary toward the
researcher under this Agreement
3) the obligation of the researcher to complete and submit - at the
end of the training - the evaluation questionnaire and - two
years later- follow-up questionnaire provided by the REA

 Obtain the researcher’s employment contract or

corresponding agreement,

 Regarding the information, the Beneficiary should have

notified the Researcher about key elements of the grant:
a) basic facts about the MSCA programme (including
researcher's rights and obligations) and where to
look for details (MSCA website, Participant portal,
MSCA Alumni Association (MCAA)...)
b) specific action in question (planned secondments,
events,...)
c) whom they have appointed to supervise him/her
for the duration of the research training activities,
including during secondments to partner
organisations.

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 Art INFORMATION TO THE 22 INFORMATION TO THE RESEARCHER: the beneficiary has to inform
32.1. RESEARCHER IF the researcher on the following aspects:
(e) 1) the description, conditions, location and the timetable for the
implementation of the research training activities under the
action and the name of the supervisor
2) the rights and obligations of the beneficiary toward the
researcher under this Agreement
3) the obligation of the researcher to complete and submit - at
the end of the research training activities - the evaluation
questionnaire and - two years later- follow-up questionnaire
provided by the REA

 Obtain the researcher’s employment contract or

corresponding agreement,

 Regarding the information, the Beneficiary should have

notified the Researcher about key elements of the grant:
a) basic facts about the MSCA programme (including
researcher's rights and obligations) and where to
look for details (MSCA website, Participant portal,
MSCA Alumni Association (MCAA)...)
b) specific action in question (planned secondments,
events,...)
c) whom they have appointed to supervise him/her
for the duration of the research training activities,
including during secondments to partner
organisations.
Art INFORMATION TO THE 22 INFORMATION TO THE SECONDED STAFF MEMBERS: the beneficiary
32.1. SECONDED STAFF RI has to inform the seconded staff members on the following
(h) MEMBERS SE aspects:
1) the description, conditions, location and the timetable for the
implementation of the secondment under the action
2) the rights and obligations of the beneficiary toward the
seconded staff members under this Agreement
3) the obligation of the seconded staff members to complete and
submit - at the end of the secondment - the evaluation
questionnaire and - two years later- follow-up questionnaire
provided by the REA.
4) the arrangements related to the intellectual property rights
between the beneficiary and the seconded staff members –
during the implementation of the secondment and afterwards;
5) the obligation of the seconded staff members to maintain
confidentiality;
6) the obligation of the seconded staff members to ensure the
visibility of EU funding in communications or publications and
in applications for the protection of results.

Obtain the employment contract or other types of working

agreements and review those statements as well as all other
relevant correspondence with the staff member.

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 Art SPECIFIC 23 Ensure that:
32.1. REQUIREMENTS ITN 1) the researchers do not receive, for activities carried out in the
(g, i, frame of the action, other incomes than those received from the
to o) beneficiary (or any other entity referred in the Annex 1)
2) (only as of MGA Version 5.0) the researchers do not have to
bear any costs for the implementation of the action as
described in Annex 1;
3) the Beneficiary host the researcher at their premises (only as
of MGA Version 3.0: or at the premises of an entity with a
capital or legal link) and provide training as well as the
necessary means for implementing the action or ensure that
such training and means are provided by entities with a capital
or legal link
4) the researcher is adequately supervised
5) a career development plan is established and support its
implementation
6) when applicable, ensure that the researcher has appropriate
exposure to the non-academic sector
7) the Beneficiary assist the researchers in the administrative
procedures related to their recruitment
 Review the accounting entries in order to ascertain whether
other income has been recorded under the action.
Regarding the potential double financing of the action, the
auditor has to raise the question to the Beneficiary and/or
to the interviewed researchers.
 Review the supporting documents evidencing the trainings
made for the fellow;
 Review documents evidencing the implementation of the
action;
 Review documents evidencing that the researcher was
hosted at the beneficiary's premises (only as of MGA
Version 3.0or the premises of an entity with a capital or
legal link to the beneficiary mentioned in Annex I to the
GA);
 Verify whether the researcher is supervised, for example
by checking evidence that demonstrates that reports were
submitted, self-declaration from the researcher or
management representations, etc. Note that the frequency
of formal reports may vary depending on the experience of
the researcher.

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 Art SPECIFIC 23 Ensure that:
32.1. REQUIREMENTS IF 1) the researcher does not receive, for activities carried out in the
(d, f frame of the action, other incomes than those received from the
to k) beneficiary (or any other entity referred in the Annex 1)
2) (only as of MGA Version 5.0)the researcher does not have to
bear any costs for the implementation of the action as
described in Annex 1.
3) the Beneficiary host the researcher at their premises (only as
of MGA Version 3.0: or at the premises of an entity with a
capital or legal link) and provide training as well as the
necessary means for implementing the action (or ensure that
such training and means are provided by entities with a capital
or legal link)
4) the researcher is adequately supervised
5) at the beginning of the research training activities — a career
development plan is established together with the supervisor
6) the Beneficiary assist the researcher in the administrative
procedures related to the recruitment

 Review the accounting entries in order to ascertain whether

other income has been recorded under the action.
Regarding the potential double financing of the action, the
auditor has to raise the question to the Beneficiary and/or
to the interviewed researchers.
 Review the supporting documents evidencing the trainings
made for the fellow;
 Review documents evidencing the implementation of the
action;
 Review documents evidencing that the researcher was
hosted at the beneficiary's premises (only as of MGA
Version 3.0: or the premises of an entity with a capital or
legal link to the beneficiary mentioned in Annex I to the
GA);
 Verify whether the researcher is supervised, for example
by checking evidence that demonstrates that reports were
submitted, self-declaration from the researcher or
management representations, etc. Note that the frequency
of formal reports may vary depending on the experience of
the researcher.

Art SPECIFIC 24 The beneficiary has to support the secondment of the researcher in
32.1.l REQUIREMENTS IF a Member State or H2020 associated country (a secondment is not
) mandatory, but in case it is undertaken, the beneficiary needs to
support the researcher):
 for actions with a duration up to 18 months: for a
maximum of three months
 or for actions with a duration of more than 18 months: for
a maximum of six months.

Obtain from the Beneficiary the evidence of support to the

researcher.

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 Art SPECIFIC 25 Secondments are possible for up to 30% of the fellowship duration
32.1. REQUIREMENTS ITN (except for EID and EJD – where time spent at other participating
(p) organisations, in line with the proposal description, is not affected
by this limitation).

According to the documentation collected from the Beneficiary (i.e.

contract agreement, research activity reports, etc.) evaluate
whether the limit of 30% of the actual months spent have been
respected as described above.
Art SPECIFIC 26 Ensure that the rights and obligations of the seconded staff
32.1 REQUIREMENTS RI members remain unchanged during the secondment.
(b) SE
Obtain evidence that salary paid/employment conditions and
obligations in the contract agreement before and during the
secondment were the same (given the top-up allowance is intended
to cover only the additional costs during secondments, the normal
salary of the seconded staff needs to remain upheld and
unchanged during the secondment – i.e. the beneficiary cannot
substitute the normal salary with the top-up allowance)
Art SPECIFIC 27 Ensure that the seconded staff members are reintegrated after the
32.1( REQUIREMENTS RI secondment.
c) SE
Verify if the seconded staff members have been reintegrated after
the secondment (either through a new employment contract after
the secondment or under the existing employment contract)
Art SPECIFIC 28 The seconded staff members are covered by an appropriate
32.1 REQUIREMENTS RI medical insurance scheme.
(e) SE
Check if the seconded staff members are covered by a medical
insurance scheme for the duration of their secondment, either
foreseen in their employment contract or purchased additionally for
the time of secondment.
Art SPECIFIC 29 The staff members must be seconded full time. The staff members
32.1 REQUIREMENTS RI cannot hold two MSCA grants at the same time.
(f) SE
Obtain the employment contracts or other type of working
agreement and review in particular the full time aspect of the job.
Art SPECIFIC 30 The Beneficiary must:
15.1. REQUIREMENTS CO  ensure that researchers are provided with the means to
2. FU carry out the research training activities (including the
and ND infrastructure, equipment and products);
Articl  ensure that researchers receive appropriate assistance in
e all administrative procedures before national authorities;
15.1.  ensure that researchers are employed full-time, unless
1(d) duly justified for reasons associated with personal or
family reasons;
 ensure that researchers work exclusively on the research
training activities;
 ensure that the research training activities (including
activities raising ethical issues and research on human
embryos or human embryonic stem cell) comply with the
ethical principles set out in Article 34;
 ensure that the researchers are informed that they are
‘Marie Skłodowska-Curie fellows’;
 ensure that researchers are paid in accordance with their
contract (employment contract, other direct contract or
fixed-amount fellowship agreement);
 ensure that the contract (employment contract, other

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 direct contract or fixed-amount fellowship agreement)
complies with the provisions of this Agreement and
specifies the research training activities;
 ensure that the contract (employment contract, other
direct contract or fixed-amount fellowship agreement)
specifies arrangements relating to confidentiality and
intellectual property rights (in particular to access to
background, use of foreground, promoting the action) —
during the research training activities and afterwards;
 inform the researchers about their obligation to complete
and submit — at the end of the research training activities
— the evaluation questionnaire and — two years later —
follow-up questionnaire provided by the REA;
 for Doctoral programmes only: appoint a supervisor with
adequate experience to provide the researchers with
academic support and a career plan
 in case of partner organisations implementing the
programmes: ensure that the partner organisations
comply with the obligations set out in Article 15 and that
the Commission and the Agency, the European Court of
Auditors (ECA) and the European Anti-Fraud Office (OLAF)
can exercise their rights under Article 22 and 23 also
towards those third parties;
 (only as of MGA Version 5.0) Recruited researchers
should not have to bear any costs for the implementation
of the action as described in Annex 1.
 For doctoral programmes: recruited researchers must NOT
be requested to pay visa-related fees or tuition fees for
their research training and/or PhD programme (e.g. student
registration, access to student services (library, computing,
etc.), teaching, supervision, examination and graduation)
neither from their own funds, nor from the researcher unit
cost.
 For fellowship programmes: the recruited researchers must
NOT be requested to pay visa-related fees or tuition fees
for their research training neither from their own funds,
nor from the researcher unit cost.

Obtain the employment contracts/fellowship agreements and

review in particular the full aspect of the requirements.

Art Promoting the 31 PROMOTION OF THE ACTION AND RESULTS: The beneficiaries must
38.1. Action: Visibility of ITN promote the action and its results by providing targeted
1 the EU funding information to multiple audiences (including the media and the
public) in a strategic and effective manner. This does not change
the dissemination obligations in Art 29, the confidentiality
obligations in Art 36 or the security obligations in Art 37, all of
which still apply. Before engaging in a communication activity
expected to have mainstream media coverage the beneficiaries
must inform the Agency (Art 52).

Obtain management representations and 3rd party documentation

provided by the auditee (all the communication support developed
to satisfy the conditions: prints, TV, radio, electronic means, etc.).

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 Art Promoting the 31 PROMOTION OF THE ACTION AND RESULTS: The beneficiaries must
38.1. Action: Visibility of IF promote the action and its results by providing targeted
1 the EU funding information to multiple audiences (including the media and the
public) in a strategic and effective manner. This does not change
the dissemination obligations in Art 29, the confidentiality
obligations in Art 36 or the security obligations in Art 37, all of
which still apply. Before engaging in a communication activity
expected to have mainstream media coverage the beneficiaries
must inform the Agency (Art 52).

Obtain management representations and 3rd party documentation

provided by the auditee (all the communication support developed
to satisfy the conditions: prints, TV, radio, electronic means, etc.).
Art Promoting the 31 PROMOTION OF THE ACTION AND RESULTS: The beneficiaries must
38.1. Action: Visibility of RI promote the action and its results by providing targeted
1 the EU funding SE information to multiple audiences (including the media and the
public) in a strategic and effective manner. This does not change
the dissemination obligations in Art 29, the confidentiality
obligations in Art 36 or the security obligations in Art 37, all of
which still apply. Before engaging in a communication activity
expected to have mainstream media coverage the beneficiaries
must inform the Agency (Art 52).

Obtain management representations and 3rd party documentation

provided by the auditee (all the communication support developed
to satisfy the conditions: prints, TV, radio, electronic means, etc.).
Art Promoting the 31 PROMOTION OF THE ACTION AND RESULTS: The beneficiaries must
38.1. Action: Visibility of CO promote the action and its results by providing targeted
1 the EU funding FU information to multiple audiences (including the media and the
ND public) in a strategic and effective manner. This does not change
the dissemination obligations in Art 29, the confidentiality
obligations in Art 36 or the security obligations in Art 37, all of
which still apply. Before engaging in a communication activity
expected to have mainstream media coverage the beneficiaries
must inform the Agency (Art 52).

Obtain management representations and 3rd party documentation

provided by the auditee (all the communication support developed
to satisfy the conditions: prints, TV, radio, electronic means, etc.).
Art EU EMBLEM 32 INFORMATION ON EU FUNDING EU EMBLEM : Unless the REA
38.1. ITN requests or agrees otherwise or unless it is impossible, any
2 communication activity related to the action (including in electronic
form, via social media,…) and any infrastructure, equipment and
major results funded by the grant must: a) display the EU emblem
and b) include the following statement: For communication
activities: "This project has received the European union's Horizon
2020 research and innovation programme under the Marie
Skłodowska-Curie grant agreement N°..... . For infrastructure,
equipment and major results: "This (infrastructure, equipment, type
of result) is part of a project that has received funding from the EU
Horizon's 2020 research innovation programme under Marie
Skłodowska-Curie grant agreement N°.... . When displayed
together with another logo, the EU emblem must have appropriate
prominence.

Obtain all the communication support and check the existence of

the EU emblem, its prominence and whether it is mentioned that
the activities were financed under the Marie Skłodowska-Curie
Actions.

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 Art EU EMBLEM 32 INFORMATION ON EU FUNDING EU EMBLEM: Unless the REA
38.1. IF requests or agrees otherwise or unless it is impossible, any
2 communication activity related to the action (including in electronic
form, via social media,…) and any infrastructure, equipment and
major results funded by the grant must: a) display the EU emblem
and b) include the following statement: For communication
activities: "This project has received the European union's Horizon
2020 research and innovation programme under the Marie
Skłodowska-Curie grant agreement N°..... . For infrastructure,
equipment and major results: "This (infrastructure, equipment, type
of result) is part of a project that has received funding from the EU
Horizon's 2020 research innovation programme under Marie
Skłodowska-Curie grant agreement N°.... . When displayed
together with another logo, the EU emblem must have appropriate
prominence.

Obtain all the communication support and check the existence of

the EU emblem, its prominence and whether it is mentioned that
the activities were financed under the Marie Skłodowska-Curie
Actions.
Art EU EMBLEM 32 INFORMATION ON EU FUNDING EU EMBLEM: Unless the REA
38.1. RI requests or agrees otherwise or unless it is impossible, any
2 SE communication activity related to the action (including in electronic
form, via social media,…) and any infrastructure, equipment and
major results funded by the grant must: a) display the EU emblem
and b) include the following statement: For communication
activities: "This project has received the European union's Horizon
2020 research and innovation programme under the Marie
Skłodowska-Curie grant agreement N°..... . For infrastructure,
equipment and major results: "This (infrastructure, equipment, type
of result) is part of a project that has received funding from the EU
Horizon's 2020 research innovation programme under Marie
Skłodowska-Curie grant agreement N°.... . When displayed
together with another logo, the EU emblem must have appropriate
prominence.

Obtain all the communication support and check the existence of

the EU emblem, its prominence and whether it is mentioned that
the activities were financed under the Marie Skłodowska-Curie
Actions.

141
 Art EU EMBLEM 32 INFORMATION ON EU FUNDING EU EMBLEM: Unless the REA
38.1. CO requests or agrees otherwise or unless it is impossible, any
2 FU communication activity related to the action (including in electronic
ND form, via social media,…) and any infrastructure, equipment and
major results funded by the grant must: a) display the EU emblem
and b) include the following statement: For communication
activities: "This project has received the European union's Horizon
2020 research and innovation programme under the Marie
Skłodowska-Curie grant agreement N°..... . For infrastructure,
equipment and major results: "This (infrastructure, equipment, type
of result) is part of a project that has received funding from the EU
Horizon's 2020 research innovation programme under Marie
Skłodowska-Curie grant agreement N°.... . When displayed
together with another logo, the EU emblem must have appropriate
prominence.

Obtain all the communication support and check the existence of

the EU emblem, its prominence and whether it is mentioned that
the activities were financed under the Marie Skłodowska-Curie
Actions.
Art Audit Sample – 33 For COFUND actions implemented by partner organisations:
18.1. COFUND Programme CO Select sample of researchers for testing - 1) if the population of
2 implemented by partner FU researchers is less or equal to 5 items, all researchers should be
organisations ND tested; or 2) if the population is more than 15 researchers select
for testing a maximum of 15 researchers. Select for testing all the
researchers with a value higher or equal to 10% of the costs
declared. Add randomly selected researchers until 50% coverage is
achieved or the total maximum number of 15 researchers is
reached.

Ensure that at least 5 different partner organisations are included

in the selected sample. If there are less than 5 partner
organisations, ensure that at least one researcher from each
recruitment partner has been selected.
Art. Systemic or recurrent 34 For COFUND actions implemented by partner organisations:
6.1 errors – COFUND CO If systemic or recurrent errors are identified, request the
Programme FU Beneficiary to recalculate the declared costs by removing the
implemented by partner ND effect of the systemic or recurrent errors for all the researchers.
organisations Verify the accuracy and reliability of the recalculation performed
by the Beneficiary.

142