Frequently Asked Questions

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Intro

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The folllowing section contains FAQ's of general interest, as well as questions referring specifically to the 1st call and the 2nd call for proposals. 

Properties

  • Duration of the call 15th of September (2nd call) and 15th of November (1st call for proposals)
  • The indicative budget of this call 44 million euro (22 million euro for the 1st call and 22 million for the 2nd call for proposals)

Content

General Questions

1. What is the overall Programme's budget?

The total budget of the HUSKROUA Programme 2014-2020 is 81,347 million EUR, comprising of 73,952 million EUR EC Funding and 7,395 million EUR co-financing. For an overview of the budget allocation between the Programme’s Thematic Objectives, please consult Section 7.1 – Thematic objectives of the JOP.

2. What are the co-financing rates for the partners in different countries?

The ENI grants may not finance the entire eligible cost of the Project and in the same time the grant may not exceed 90 % of the total forecasted eligible costs of the Project, nor be below 50%. The co-financing shall amount to at least 10% of the total eligible costs of the Project. In case of grant Lead Beneficiaries/Beneficiaries registered in participating Member States, a maximum 5% of the total eligible costs of the Project (50% of the co-financing) will be funded from the national budget. The remaining minimum 5% of the total eligible costs of the Project (50% of the co-financing) has to be covered from the Lead Beneficiary’s/Beneficiary’s own contribution or from sources other than the European Community budget or the European Development Fund.

3. May some of the partners be exempt from co-financing the project?

It is possible that one partner does not co-finance the project. However, it is highly recommended that all partners provide the same percentage of co-financing in comparison to their financial inputs, so as to ensure an equal treatment.  In the same time it is important to prove that all partners have adequate financial capacity to implement the project.

4. What is the minimum requirement for setting up a partnership? 

At least two partners – one from the Member State participating in the Programme and one from Ukraine - can set up a partnership and submit a project proposal. All partners must comply with the eligibility criteria described in the relevant sections 2.1.1 of the Guidelines for Applicants.

5. What is the Lead Partner principle and who can act as Lead Partner? 

The “Lead Partner principle” means that each partnership appoints one organization to act as Lead Partner. In the application stage, the Lead Partner is referred to as “Lead Applicant”. After the signature of the Grant Contract, the “Lead Applicant” becomes the "Lead Beneficiary". The Lead Beneficiary takes financial and legal responsibility for the implementation of the entire project (Section 2.1.2 describes its responsibilities; please also check the Partnership agreement and the Grant Contract for an informed view on the responsibilities of the Lead Beneficiary) and who will act as the only direct contact between the project and the management bodies of the Programme.

6.  Which organizations are bodies governed by public law?

Body governed by public law, as defined in Article 1.9 of Directive 2004/18/EC means any legal body established for the specific purpose of meeting needs in the general interest, not having an industrial or commercial character, and financed, for the most part, by the State, regional or local authorities, or other bodies governed by public law; or subject to management supervision by those bodies; or having an administrative, managerial or supervisory board, more than half of whose members are appointed by the State, regional or local authorities, or by other bodies governed by public law.

7.  What criteria (method of verification) are used to determine whether an entity is located in the eligible area?

The statutes or articles of association of the Lead Applicant organization and of the other project Applicants in both original language supplemented by a brief English translation is supposed to provide a sufficient method of verification on the location of the entity. Please ensure that in your brief translation in English such information is enclosed.

Where the Lead Applicant or the Applicants are public body created by a law, the Statutes or Articles of association are not required. In such cases the Lead Applicant/ Applicants should submit a statement referring to the relevant legal act.

8.  Is there a limitation for an organization to participate as a partner in several partnerships?

The Lead Applicants as well as other Applicants may take part in more than one application and a Lead Applicant may at the same time be Applicant in other applications. Such entities may be awarded more than one grant under this Call for Proposals, if it can demonstrate its financial and administrative capacity of managing and co-financing all the awarded projects. Concentration of grants in some entities can be considered a risk factor and should be discussed by the Joint Monitoring Committee and consequently may lead to a rejection of the Project Application.  

9.    What are the opportunities to find a project partner?

One can send his/ her project idea by using this template (downloadable document) for which he/she is searching a partner to be posted on the Programme’s webpage (Project ideas database section) together with the contact details.

10.    Can the activities take place outside the eligible area?

Please note that whatever activities one project may be proposed, they have to be located in the eligible areas as stated in the Guidelines section 1.2.

11.  Are existing staff’s salaries eligible?

Yes, such costs are eligible under the conditions that they do not exceed those normally borne by the Beneficiary or its partners and in the same time comply with the national laws they are subject to. As such, especially in the case of civil servants, it is highly advisable to consult the national legislations and consult the National Authority for the legal provisions one needs to comply with.

12.  Administrative costs (overheads or indirect costs) are eligible costs only for the Lead Applicant or for all Applicants?

The indirect costs are those that cannot be explicitly identifiable as specific costs directly linked to the performance of the project, but which can be identified and justified by the Lead Beneficiary/Beneficiary using his accounting system as having been indirectly incurred in connection with the eligible direct costs of the project.

These costs may be claimed by the grant Lead Beneficiary as well as by all other beneficiaries if agreed so in the budget, within the maximum limit of 2% of the total direct eligible costs (per project) entered in the budget without infrastructure component, but less than 60.000 EUR per applicant and per project. This flat-rate covers the indirect costs of the project and for which the Beneficiary does not need to provide supporting documents. However the basis for calculation for these costs should be assessed during the project evaluation phase. Please note that this does not put a limit to the actual administrative costs of a beneficiary. If the real costs are higher than 2%, the grant beneficiary may claim them as direct costs on the condition that the required supporting documents can be provided.

Costs of budget heading “5 Project dedicated office” is designed mostly for small organizations, while large public entities or organizations should use the budget heading “7. Administrative costs”. However, heading 5 and 7 cannot be used for the same organization. 

13. Can we initiate procurement procedures before the start of the initiation of implementation period?

Procedures to award subcontracts for goods/services/works used/provided/delivered during the implementation period may have been initiated but contracts may not be concluded by the beneficiary or its partners before the start of the implementation period of the project.

14.   Is there a maximum value for the salaries, travel and subsistence costs of the staff employed in the team of the project?

Salaries as well as subsistence costs must not exceed those normally borne by the Beneficiary or its partners. In the same time, travel and subsistence costs for staff and other persons (project staff & representatives of the Lead Applicant/Applicant(s)) taking part in the project’s implementation are eligible under the condition that they  exceed neither those normally borne by the Beneficiary or its partners, according with national legislation applicable for each type of legal entity nor the rates published by the Commission at the time of the mission if reimbursed. The MA as well as the JTS may require additional information and supporting documents in case there will be doubts concerning the requested levels.  

15.   Are the contributions in kind eligible?

Any contributions in kind do not eligible costs. The contributions in kind may not be treated as co-financing by the Beneficiary or its partners. However, the cost of staff assigned is not a contribution in kind and may be considered as co-financing in the Budget of the project when paid by the Beneficiary or its partners. 

16.  Are the travels to other locations outside the eligible area eligible?

Costs outside the eligible area are not eligible. In line with section 2.1.3 of the Guidelines for Applicants for the 1st and also for the 2nd Call for Proposals the projects may not be implemented in regions other than those defined in point 1.2 as Programme eligible area.

17.   Should the VAT be included in the budget of the project?

The Lead Beneficiary and its partners could fall into one of the following situations and should act accordingly:

-       Organisations which are not entitled to recover any paid VAT by whatever means should include VAT in the costs;

-       Organisations which are entitled to recover any paid VAT by whatever means should not include VAT in the costs;

-       Organisations which are partially entitled to recover any paid VAT by whatever means, should not include VAT in the costs.

-       For the partially non-recoverable paid by whatever means, the organisations should include VAT in the costs. 

18.   Can we submit unofficial translations of the documents?

Unofficial translations are accepted as well, but in any case, such a translation has to be certified by the legal representative of either the Lead Applicant or by the other Applicants on the case. Translations are not requested for any of the documents. However, English summary shall be submitted in the following cases: The Statutes or Articles of association of the Lead Applicant and Applicant organisation(s) shall be provided in original language accompanied with brief English summary (max. 1 page), reflecting the main content. The full feasibility study and Environmental Impact Assessment may be submitted in original language accompanied with brief English summary, reflecting the main content.

19. Can we get more information on the state aid rules?

State aid rules apply only to measures that satisfy all of the criteria listed in Article 107(1) of the Treaty, and in particular the followings:

The recipient is an undertaking

The recipient of the aid is an “undertaking”, which is carrying out an economic activity regardless of their legal status and regardless of whether they aim to make a profit or not.

The applicant shall examine every planned activity within the project. Economic activity may mean that the beneficiary provides service or sells products for payment. For example if the beneficiary undertakes to renew a church within the project and then sells tickets to visitors, it may mean economic activity. If the price of the ticket covers the maintenance costs then its not state aid relevant activity.

Transfer of state resources

State aid rules cover only measures involving a transfer of State resources (including national, regional or local authorities, public banks and foundations, etc.).

This criteria is always „yes” – its an immanent part of the programme - thus no option is provided.

Granting of an advantage

Aid (directly or indirectly) distorts or threatens to distort competition (all advantages have to be taken into account). The aid should constitute an economic advantage that the undertaking would not have received in the normal course of business.

The applicant shall declare if they could finance the activity from other sources.

Selectivity of the measure

Aid favours certain undertakings or the production of certain goods.

Since not every project will be granted, this criteria is always „yes” – its an immanent part of the programme - thus no option is provided.

Possible distortion of competition between Member States

Aid affects trade between Member States because the concerned activities are open to competition in various Member States.

The applicant shall examine who would be the potential clients regarding the project activities. For example if the visitors of the church would be only natives, the answer is no. If the visitors are mostly foreigners, they need further inquiry. If the tourists come because of the famous spa of the town, then its not state aid relevant activity. Or considering the few amount of visitors it may not be state aid relevant activity.

 If all the criterias are relevant for the applicant (5 „yes”), then its a state aid relevant activity (even if one answer is „no”, its not state aid relevant). In case of „no” answer we expect a short explanation. The filled and signed state aid declaration (self assessment) shall be submitted by each and every applicant. The Managing Authority will examine every project and evaluate if any activity of the project is state aid relevant (assessment of the Managing Authority). Based on the result of the evaluation, the Managing Authority may recommend modifications.

20. Both guidelines for Applicants of the 1st and 2nd calls for proposal mention the provision that "Exceptionally and in duly justified cases, the Managing Authority may accept a later submission of the Building permit". What are the situations that would justify such cases?

Such situations may indeed occur and during the project developing and submission phase the LA/ Applicants must provide in any case a proof/ certificate that they have launched already the procedures to the relevant authorities in order to obtain the necessary building permit. This information as well as the expected time of obtaining it must be reflected in the section that tackles the readiness to start the project implementation. Please be aware that providing the justification/ documentation for such a case does not mean automatically acceptance from the MA.

During the administrative and eligibility check, the applicants will be asked to provide further clarifications on the status of obtaining the building permit or will be asked to provide it. 

2nd call for proposals

1. How shall a project be submitted for the second calls for proposals?

Applicants must submit their applications via the IMIS 2014-2020 Application Module  which will be available for users as early as August 2017. Meanwhile the offline template of the Grant Application Form (Word version) is to be used as informative and preparatory material as it reflects the content of the online module.

2. The Guidelines states that “Each Lead Applicant should use at least one or more indicators (key outputs) pre-defined in the table below”. This section contains two tables: one table Result Indicators (page 33) and one table Output Indicators (page 34). As the Guidelines specifically mention “key outputs”, we would like to ask you to clarify if both these indicators are mandatory or only the output indicators.

Section 2.7.1 of the Guidelines refers in general terms to both program and projects’ indicators. When developing a project, in the offline Application Form (available in Word format) one is  required to mention which Programme Output indicator(s) and, similarly which Programme Result Indicator(s), the project contributes to and one will refer to the Programme results and output indicators mentioned in the two tables (page 33-35 of the Guidelines for Applicants). Moreover some specific project indicators (both results and outputs) will have to be defined as well taking into account the nature of your project. One has to also take into account the terminology defined in the Guidelines for Applicants when referring to the results, outputs, impact and outcomes (page 33 of the Guidelines for Applicants).

In conclusion, in order for projects to be fully aligned with the Programme’s strategy and in the same time to maximize their score in the quality assessment, it is highly recommended that the projects use at least one of the programme level result indicators (name of the indicators and measurement unit) and at least one programme level output indicator. In this way the Programme can gather aggregate data both before, during and at the end of projects’ implementation and get an overview on what has been funded and what were the programme’s outputs, results and in the end impact and further what could be policy interventions. Of course projects can in addition come up with their specific own indicators as well (results and outputs). Moreover, projects shall come up with their specific own project level indicators as well (results and outputs).

3. How the expression “audited Annual accounts” should be interpreted? It is a mandatory condition for all the Applicants, as an eligibility criteria, to have theirs annual accounts audited by independent auditors, even if this is not a requirement under the national law?

The expression "audited annual accounts" means, in case the legislation does not oblige an organization to run such an audit, to submit together with the application the approved annual accounts for the last two closed financial years. In conclusion one can dismiss the term “audit(ed)” in case the legislation does not oblige, but still needs to provide the approved annual accounts for the last 2 closed financial years.

1st Call for Proposals

1. What are the documents related to the LIP Call for Proposals and where can I find them?

The exhaustive list of documents one needs to consult prior to submitting a project proposal is the following:

The Hungary-Slovakia-Romania-Ukraine Cross-border Cooperation Programme 2014-2020 available at http://www.huskroua-cbc.net/uploads/editors/HUSKROUA%20JOP_final_23112016.pdf

The Call for Proposal Application Package:

-         The Call for Proposals;

-         The Guidelines for Applicants;

-         The documents that needs to be filled in by the applicants: the application form, and annexes 1-6, the budget, the financial plan of the project, the supporting documents and the additional supporting documents in case of investment projects as well as the documents for information (Section 3 in the Guidelines for Applicants – Documents to be submitted).

2. What is the deadline for submission of applications?

The deadline for submitting the application is the 15th of November 2017 as evidenced by the date of dispatch, the postmark or the date of the deposit slip. In the case of hand-deliveries, the deadline for receipt is at 14:00 local time as evidenced by the signed and dated receipt. Any application submitted after the deadline will automatically be rejected. However, for reasons of administrative efficiency, the Joint Monitoring Committee may reject any application sent before the deadline, but received after the effective date of approval of the administrative and eligibility check (see indicative calendar under section 2.4.2 of the Guidelines for Applicants).

3. Is it possible to apply with a project proposal combining for example Thematic Objective 6 and Thematic Objective 7 of the programme?

Each project can target only one Thematic Objective and one Priority. Contributions to other Priorities and programme specific objectives are however possible.

4. Where and how should we send the applications?

Applications must be submitted in one original and as many copies as the number of countries involved in the Partnership but not less than 2 copies. Applications must be submitted in one package in a sealed envelope by registered mail, private courier service or by hand-delivery (a signed and dated certificate of receipt will be given to the deliverer) at the following address: HU-SK-RO-UA ENI CBC Programme Joint Technical Secretariat Széchenyi Programme Office Nonprofit Llc. H-1053 Budapest, Szép street 2, 3rd floor, room A302 . Applications sent by any other means (e.g. by fax or by e-mail) or delivered to other addresses will be rejected. Applicants must verify that their application is complete using the Checklist (section 10 of the Grant Application Form). Incomplete applications may be rejected.

5. May I have a prior opinion of the JTS/ MA on the eligibility of a partner or a project proposal?

The applicants (the Lead Beneficiary) can request for individual consultations with the JTS and can touch all aspects of the application process during such a meeting. The request is to be sent via email and should include a written project outline. However, in order to ensure the equal treatment of applicants and partners, the JTS may not give a prior opinion on the eligibility of an Applicant, a partner, a project proposal or specific activities. One must also take into account that the the Joint Monitoring Committee is the only Programme body entitled to make last decisions on elibility of applicants and projects.

6.  When a project is considered to have a cross-border impact?

The projects should always have a cross-border character, from their very start and application development to objectives definition and detailed activities planning and implementation. On more concrete terms, the below four cooperation criteria need to be respected in the projects of all nature:

  1. Joint project development: the project must be designed in common by partners meaning that applications must clearly integrate the ideas, priorities and actions of all stakeholders. The Lead Applicant is the coordinator of this process but should include other partners from the beginning of the development process;
  2. Joint project implementation: the activities to be carried out for the implementation of the project are distributed in a balanced way among the partners and are correlated with the applicants’ expertise.
  3. Joint staffing: the project should not duplicate functions while in the same time being aligned with the requirements stemming from project activities, the grant contract and the partnership agreement. For example, the Lead applicant should appoint a project manager for the overall project coordination and a financial manager in charge of the overall project financial implementation, as well as a communication manager. Applicants on the other hand should appoint a project manager responsible for its part of project implementation and a financial manager.
  4. Joint financing:  only one grant contract will be signed and there will be a common budget while the reporting is carried out in common. There will be only one project bank  held by the  Lead Applicant and payments (from ENI) are made from the programme to this account. The Lead Applicant (Beneficiary) is responsible for the administration and distribution of these funds to the partners and for reporting on their use. Co-financing should be provided by each partner illustrating the commitment by each partner to the project.

7. Are project preparation costs eligible?

Preparatory costs are not eligible for the present call of proposals.

8.  Which exchange rates should be used in conversions of the amounts to be typed in the Grant Application Form?

According to Article 67 of the ENI CBC IR, expenditures occurred in national currency of the participating countries other than EUR will be converted into EUR using the monthly accounting exchange rate of the Commission of the month during which the expenditure was submitted for examination in accordance with Article 32(1) of the Implementing Regulation. This method shall be set out and shall apply throughout the programme duration, both to the expenditures related to technical assistance and to the expenditures related to projects.

9.  Does the Application Form have to be signed?

The Application Form does not need to be signed, however, its annexes together with certain supporting documents need to be provided in original and has to bear the signature and stamp of the representative of the organization acting as Lead Applicant or as Applicant. Please refer to section 2.2.1 for the procedure to follow and documents to provide.

10. If a project will not contain any construction works, will it be regarded as a LIP project?

  • According to the art.2(p) of the Commission regulation No 897/2014, “large infrastructure projects’ means projects comprising a set of works, activities or services […] for the purposes of implementing investments";
  • According to the Guidelines for Applicants, the investment type of the projects are projects which contain construction, work and/or supply components;

Taking into account the stated above, the infrastructure component in a large infrastructure project refers to infrastructure investment in the project e.g. construction or renovation works of physical facilities and systems.

11. In case we have partners from each eligible country of the programme, do we need a letter of support from each administration (county/oblast) involved in the project? Do these public administrations from eligible areas have to be partners as well in the project?

According to the point 2.2.1 of the Guidelines for applicants for the 1st Call for Proposals, all Applicants shall obtain letters of support from the relevant regional authorities proving the strategic importance of the planned project idea. In case you have partners from each eligible country of the Programme, you have to provide Letters of support for the project idea from each concerned administration (county/oblast). These Letters are necessary to prove that the project is of strategic importance for the regional authorities, which should not obligatory be partners in the project. The letters should also be translated in English, but unofficial translation should be sufficient.

12. Are expenditures related to feasibility study and other documents related to technical documentation, building permit, environmental approvals for construction work eligible costs, taking into account the fact that they will be made before the official duration of project implementation?

Retroactive costs incurred before grant contract signature are not eligible costs.

13.  Would a non-final building permit submitted as part of the Application be acceptable?

Exceptionally and in duly justified cases, the Managing Authority may accept a later submission of the Building permit. Therefore, the submission of a non-final building permit (as a proof that the request is already submitted to the relevant authority) would be acceptable.

14. What are the available funds for the first opened Call for Proposals and the minimum and maximum size of the grant?

The indicative financial allocation for the LIP call for proposals (HUSKROUA/1701/LIP) is 22 million EUR, however the Joint Monitoring Committee reserves the right not to award all available funds and to reallocate the remaining funds to future Call for Proposals.

The minimum size per grant has to allocate at least 2,5 million EUR to acquisition of infrastructure with the conditions set by the Programme, while the maximum size can go up to the total financial allocation per Priority.

The financial allocation per TO and priority:

TO  6: Environmental protection, climate change mitigation and adaptation / Priority 1 Sustainable use of the environment in the cross border area - preservation of natural resources, actions to reduce GHG emission and pollution of rivers: 7,000,000 million EUR.  

TO  7: Improvement of accessibility to the regions, development of sustainable and climate-proof

-        Priority 1 Development of transport infrastructure to improve the mobility of persons and goods: 4,000,000 EUR.  

-       Priority 2 Development of ICT infrastructure and information sharing: 7,000,000 EUR

TO  8: Common challenges in the field of safety and security

-       Priority 1 Support to joint activities for the prevention of natural and man-made disasters as well as joint action during emergency situations: 4,000,000 EUR