Frequently asked questions
In the interest of the equal treatment of Applicants, the Managing Authority cannot give a prior opinion on the eligibility of an Applicant, a partner, a project or specific activities.
Questions that may be relevant to other Applicants, together with the answers, will be published in this section. It is therefore highly recommended to consult it regularly. Replies will be given within 10 days.
The Managing Authority cannot organise individual consultations with Applicants or partners following the principle of equal treatment. Public events on the call will be announced on the Programme website.
In order to view the answers to your questions, please check on a regular basis the tab “Answers" of your account the Programme website.
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1. General information on the call for capitalisation projects
Do the project, financial and communication managers have to be part of the staff of the Applicant or could they be sub-contracted? Can these roles be assigned to partners?
Published on:As per section 2.5.1 of the Guidelines for Grant Applicants, in order to guarantee a good management of the project and as a minimum requirement, the following project management positions shall be ensured by the Applicant: a project coordinator, a financial manager, and a communication manager. These key staff members should be preferably part of the permanent staff of the Lead Beneficiary. Moreover, since the overall management is considered the main responsibility of the Lead Beneficiary, the whole project management cannot be sub-contracted. This means that the overall coordination shall always remain under the responsibility of the Lead Beneficiary organization that can be supported by external experts. Despite these three main roles shall be ensured by the Applicant, this does not mean that partners cannot be involved in these activities.
What happens if, at the time of the submission of the supporting documents, there have been some changes in the name, registration number or legal representative of an institution as indicated in the e-Application Form?
Published on:Changes such as the name of the legal representative or in some cases registration number due for example to the merge of an institution with a pre-existing one are allowed, provided that these are fully explained through the supporting documents to be sent for the verification of eligibility. In particular, the supporting documents will have to prove that the institution indicated in the e-Application Form has not changed and justify the modifications regarding the above-mentioned elements. Therefore, copies of a new law, for example, that explains the merge of an institution with another one etc., must be provided. All changes should be indicated in a letter addressed to the MA attached to the supporting documents to be sent within the deadline specified by the MA in the notification letter addressed to the Applicant of the projects admitted to step 2 of the evaluation process.
2. Terms of Reference
Is it possible to capitalize projects not mentioned in Annex I?
Published on:The core projects identified for capitalisation under this Call are those contained in Annexes 1,2, 3 and 4 to the Terms of Reference (ENI CBC MED standard projects, ENPI CBC MED, Interreg MED and Union for the Mediterranean selected projects, as well as the other initiatives mentioned in the ToRs (Interreg programmes with a Mediterranean coverage, WestMED and BlueMed, PRIMA, regional and bilateral cooperation under the European Neighbourhood Instrument, etc.).
Other initiatives, programmes and projects mentioned in the ToRs, including those implemented by the United Nations and related agencies, national development agencies, international NGOs and financing institutions (World Bank, European Investment Bank, European Bank for Reconstruction and Development, KfW Group, etc.) active in the Mediterranean Partner Countries participating in the Programme, can also be considered for capitalisation, as far as it is clearly demonstrated their high potential of synergies with ENPI/ENI CBC Med projects.
In any case and depending on the Priority chosen, it is highly recommended to applicants to capitalise on different relevant projects, systematically including ENPI/ENI CBC Med projects (at least one)when designing a proposal.
3. Eligibility of Applicant and partners
Are international organisations eligible under this call for proposals?
Published on:International organisations can participate in this call following the rules set in section 4.3.2 of the Guidelines for Applicants, in particular:
- pursuant to Article 43 of the Implementing Rules of the Financial Regulation for the General Budget of the European Union, international organisation means international public-sector organisations set up by intergovernmental agreements, and specialised agencies set up by such organisations
- these organisations may have a worldwide or regional scope. Organisations created under national law are not international organisations (e.g. national NGO with several regional/country offices);
- international organisations can participate only if they have an agreement with the government of the country in which they are going to carry out project activities;
- international organisations can participate as Applicants or Partners only if they have an operational office in the eligible area (see section 4.3.2 of the Guidelines for Applicants). The said office must have the capacity to undertake legal obligations (signing contracts) and assume financial liability.
Finally, international organisations cannot be taken into consideration in calculating the minimum number of countries within a partnership. As far as the 50% rule is concerned, if an international organisation is based in a Mediterranean Partner Country (MPC), its direct costs will be calculated as part of funds managed by MPCs.
Can one organisation participate in the same project with more departments/units?
Published on:No. As stated in the Guidelines for Grant Applicants (see par. 4.4.1 footnote n. 17), “i.e. Public administrations or Universities will be considered as ONE organisation represented by ONLY ONE legal person despite the functional independence of their departments or units”. The same organisation - with one legal representative and one single registration number - cannot be represented more than once within the same project.
What are the eligibility criteria concerning the legal status of Applicants and partners?
Published on:The eligibility criteria concerning the legal status of an organisation are defined in the Guidelines for Grant Applicants (section 4.3.2). A “non-exhaustive” list is also contained in footnote n. 14 of the Guidelines for Grant Applicants. Please note that since natural persons are not mentioned in the Joint Operational Programme, they are not allowed to participate in calls for proposals as Applicant or partner (see footnote n. 15 of the Guidelines for Applicants). As a consequence, only legal entities established in accordance with national legislation, laws and regulations can participate in calls for proposals. Please note that it is in the interest of the Applicant and of the whole partnership to know the correct legal status of an organization, since this is relevant to determine the financial capacity.
4. Budget and eligible costs
What are the main rules concerning sub-grants?
Published on:According to paragraph 4.5.6 of the Guidelines for Grant Applicants, sub-grants may be awarded by the Beneficiary or partners to offer financial support to third parties (including physical persons) to be involved in carrying out some specific project activities. Sub-grantees have to be resident or established in the Programme eligible area of the participating countries of the Applicant and partners. They should be duly justified and compliant with the State Aid provisions (de minimis regime) as referred in paragraph 5.7 of the Guidelines. Moreover, according to paragraph 4.4 of the Joint Operational Programme, there are some financial limitations that apply to sub-grants:
- a maximum of amount of €60.000 can be given to each third party;
- maximum of 30% of the total direct costs of a project can be awarded as sub-grants. The amount of project direct costs to be sub-granted must be included in the Budget heading “Other costs”.
Finally, the Applicant will have to provide information on how the sub-grant procedures will be managed, on the selection criteria the indicative number of sub-grants to be awarded, the final beneficiaries and the expected impact of the sub-grants. The Programme does not foresee any specific requirement to select sub-grantees. Since sub-grantees need to be selected, their names cannot be identified priorly in the application form.
Is there a maximum amount to be allocated to expenditure verification costs?
Published on:According to footnote n. 24 of the Guidelines for Grant Applicants, “It is recommended to allocate between 2% and 3% of the total direct eligible costs for external expenditures verification”. They cannot exceed 3% of the total direct costs (note on eligible costs)
Are there any budget thresholds applying to the different Work Packages or direct cost categories?
Published on:In general terms, there is no maximum or minimum percentage of costs foreseen for the different Work Packages (WP).
As far as the direct costs are concerned, the following thresholds apply:
- Cost Category 1 “Human Resources” cannot be higher than 40% of the total direct costs;
- €10,000 at project level for preparatory costs (only travel and subsistence costs are allowed under WP0);
- maximum €60,000 per third party and up to a maximum of 30% of the total direct costs for sub-grants.
No other thresholds are foreseen for other cost categories.
Are all the organisations (private and public) included in the partnership obliged to include in the budget of the project the costs (up to 3% of the total eligible budget costs) related to the external expenditure verification?
Published on:Yes, each organisation must have its own budget for the verification of expenditure. In fact, it is not possible to have one single auditor for the entire partnership due to the need for validating the selected auditors at national level through the Control Contact Points of the participating countries. Furthermore as per footnote 24 of the Guidelines for Grant Applicants, it is recommended to set an appropriate budget for the external expenditure verification, meaning no more than 3% but no less than 2% of the total direct costs of the project.
5. Application form
What is the difference between WP0, WP1 and WP2 and the (up to 4) “technical work packages” that I may include in my project?
Published on:WP0, WP1 and WP2 are considered as “transversal” work packages (WPs) concerning preparation (WP0), management (WP1) and communication (WP2). In particular, WP0 is optional and may be considered in case - after the publication of the call and until its deadline - you have carried out preparatory activities (i.e. travel for partnership meetings) implying preparation costs up to 10.000 euro (see par. 4.5.3 of the Guidelines for Grant Applicants). These costs can be eligible, only in case your application is selected for funding. Both WP1 and WP2 are mandatory WPs, as no project may be funded without these two components. Please note that you may consider an indicative list of technical outputs to be included in these WPs (see the courtesy form). Finally, WPs from WP3 and up to WP6 are linked to the selected expected result(s) in the section “Logical Framework”. You can find the mandatory expected result(s) by Priority and an indicative list of thematic outputs in the ENI CBC Med Joint Operational Programme 2014-2020. You can identify with your partners your own outputs and include them in your proposal, even if not mentioned in the lists provided in the Joint Operational Programme.
If my organisation has several departments, which information shall I indicate in section “Applicant and partners details” of the e-application form?
Published on:Large organisations such as universities, national research centers etc., should indicate the financial and technical information at “department” level (the one involved in the project). If this information is not available, a weighted average of the overall structure divided by the number of departments according to the amount that they manage per year can be indicated. The same approach shall be followed for the calculation of the administrative cost, where a large organization could take into account the percentage of total budget managed by the department that participates in the project. The methodology used to determine the information shall be described as it may be requested by the Managing Authority during the evaluation process.