184.108.40.206. Six-pillar assessment
To be eligible, the delegatee body must comply with a number of criteria:
- the bodies concerned must offer adequate financial guarantees. Such guarantees must be underwritten by a public authority and allow full recovery of any amounts owed to the European Commission.
- the delegatee body must comply with the rules on the visibility of an EU action;
- performance of the delegated implementation tasks must not give rise to any conflicts of interest;
- bodies performing implementation tasks must conduct regular checks to ensure that actions financed by the budget/EDF has been carried out correctly; and
- the bodies concerned must take steps to prevent irregularities and fraud and, if necessary, bring legal proceedings to recover any funds wrongly paid or incorrectly used.
Furthermore, before entrusting an entity with implementation tasks under indirect centralised management, the European Commission must carry out an institutional assessment of the body (which will be reflected in the financing decision) to obtain evidence of the existence and proper operation within the delegatee body of the following (the '6-pillar assessment'):
- transparent procurement and grant procedures, which are non-discriminatory and exclude any conflict of interests and which are in accordance with the provisions of Titles V and VI of the Financial Regulation and of the rules applicable to the EDF;
- an effective and efficient internal control system for management of operations, which includes effective segregation of the duties of authorising officer and accounting officer or the equivalent functions;
- an accounting system that enables the correct use of EU funds/EDF resources to be verified and the use of funds to be reflected in the EU/EDF accounts;
- an independent external audit;
- public access to information of the level provided for in EU regulations; and
- annual ex-post publication of beneficiaries of funds deriving from the Budget/EDF, having due regard to the requirements of confidentiality and security.
The ex ante assessment of the above elements (the 'six pillars') has been centralised in unit DEVCO.R2. Once a delegation or other service has received a request regarding indirect centralised management, or has invited the body to submit a request, and after approval by DG DEVCO management, the request should be transmitted to that unit, which will contact bodies concerned and inform them of the procedure to be followed. To ensure compliance with the principle of non-discrimination, each entity interested in carrying out budget implementing tasks under the indirect centralised management mode should formally apply, indicating its willingness to be subject to an assessment to verify compliance with the six pillars. This will be done on the basis of a model letter. The organisation will also be requested to complete a form, which will enable the European Commission to carry out an initial screening and decide whether the organisation is eligible on formal grounds.
If the organisation is eligible on formal grounds, an assessment will be launched to verify whether it complies with the requirements of the Financial Regulation. This will normally be done by an external audit firm. The work will be carried out on the basis of standard terms of reference and involves examining whether the entity complies with the criteria set out in Article 56 of the EU Budget Financial Regulation 1605/2002 and Article 26 of the Financial Regulation of the 10th EDF. The terms of reference also include questions regarding third party procedures, i.e. covering situations where those organisations implement projects/programmes via implementing partners and use the national procedures of a third country.
The audit firm will prepare a report, including its opinion on how well the entity meets the requirements of the Financial Regulations and, if appropriate, recommendations.
The report will be subject to a two-way procedure, whereby the organisation will have an opportunity to express its opinion on the results of the assessment. The report will serve as a basis for the European Commission in deciding whether to entrust the entity with implementation tasks in the indirect centralised management mode. The outcome of this assessment will be circulated by DEVCO/R2 to all DG DEVCO Directors and Heads of Delegation.
Even where some questions in the questionnaire are not assessed favourably, it does not mean that the entity is not eligible to carry out budget implementation tasks. The structure, set-up and systems of an entity will differ depending on its size, legal frame etc. The authorising officer should, in deciding whether to entrust the entity with budget/financial implementation tasks, take into account not only the results of the assessment but also such things as previous records of working with the European Commission, reports and other information available about the entity.