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Step 2: Check the compliance with the Programme criteria
When developing their project and before applying for EU support, participating organisations must verify that the project respects the following criteria: eligibility, exclusion, selection and award.
The eligibility criteria mainly relate to the type of project and activities (including, where relevant, duration, participating organisations, etc.), the target group (e.g. status and number of participants involved) and the conditions for submitting a grant request for such a project (e.g. deadlines for submission, completeness of the application form, etc.).
To be eligible, the project must meet all the eligibility criteria relating to the Action under which the proposal is submitted. If the project does not meet these criteria at application stage, it will be rejected without being further evaluated. As an exception, in case of mobility activities and EMJMD Scholarships supported under Key Action 1 or Key Action 2, some eligibility criteria (e.g. duration, profile of participants, etc.) may only be verified during the stage of project implementation or at final report stage (not at application stage). At application stage, the applicants will be asked to declare that these criteria will be met by the project. However, if it appears at implementation or final report stage that these criteria have not been fulfilled, the participants or the activity may be considered ineligible with a consequent reduction/recovery of the EU grant initially awarded to the project.
The specific eligibility criteria applying to each of the Actions implemented through the Erasmus+ Programme Guide are described in Part B of the Guide.
An applicant will be excluded from participating in calls for proposals under the Erasmus+ Programme or will be rejected from the award procedure if it is found in one of the situations described below, in accordance with articles 106 and/or 107 of Eu Financial Regulation:
- the applicant is bankrupt, subject to insolvency or winding up procedures, its assets are being administered by a liquidator or by a court, it is in an arrangement with creditors, its business activities are suspended or it is in any analogous situation arising from a similar procedure provided for under national legislation or regulations;
- a final judgement or a final administrative decision has established that the applicant is in breach of its obligations relating to the payment of taxes or social security contributions in accordance with the law of the country in which it is established, with those of the country in which the authorising officer is located or those of the country of the implementation of the grant;
- a final judgement or a final administrative decision has established that the applicant is guilty of grave professional misconduct by having violated applicable laws or regulations or ethical standards of the profession to which the applicant belongs, or by having engaged in any wrongful conduct which has an impact on its professional credibity where such conduct denotes wrongful intent or gross negligence, including, in particular, any of the following:
- fraudulently or negligently misrepresenting information required for the verification of the absence of grounds for exclusion or the fulfilment of selection criteria or in the performance of a contract, a grant agreement or a grant decision;
- entering into agreement with other persons with the aim of distorting competition;
- violating intellectual property rights;
- attempting to influence the decision-making process of the Commission/Agency during the award procedure;
- attempting to obtain confidential information that may confer upon it undue advantages in the award procedure;
- a final judgement has established that the applicant is guilty of any of the following:
- fraud, within the meaning of Article 1 of the Convention on the protection of the European Communities' financial interests, drawn up by the Council Act of 26 July 1995;
- corruption, as defined in Article 3 of the Convention on the fight against corruption involving officials of the European Communities or officials of EU Member States, drawn up by the Council Act of 26 May 1997, and in Article 2(1) of Council Framework Decision 2003/568/JHA, as well as corruption as defined in the legal provisions of the country where the authorising officer is located, the country in which the applicant is established or the country of the implementation of the grant;
- participation in a criminal organisation, as defined in Article 2 of Council Framework Decision 2008/841/JHA;
- money laundering or terrorist financing, as defined in Article 1 of Directive 2005/60/EC of the European Parliament and of the Council;
- terrorist-related offences or offences linked to terrorist activities, as defined in Articles 1 and 3 of Council Framework Decision 2002/475/JHA, respectively, or inciting, aiding, abetting or attempting to commit such offences, as referred to in Article 4 of that Decision;
- child labour or other forms of trafficking in human beings as defined in Article 2 of Directive 2011/36/EU of the European Parliament and of the Council;
- the applicant has shown significant deficiencies in complying with the main obligations in the performance of a contract, a grant agreement or a grant decision financed by the Union’s budget, which has led to its early termination or to the application of liquidated damages or other contractual penalties, or which has been discovered following checks, audits or investigations by an Authorising Officer, OLAF or the Court of Auditors;
- a final judgment or final administrative decision has established that the applicant has committed an irregularity within the meaning of Article 1(2) of Council Regulation (EC, Euratom) No 2988/95;
- in the absence of a final judgement or where applicable a final administrative decision, the applicant is in one of the cases provided in (c) to (f) above based in particular on :
- facts established in the context of audits or investigations carried out by the Court of Auditors, OLAF or internal audit, or any other check, audit or control performed under the responsibility of an authorising officer of an EU institution, of a European office or of an EU agency or body;
- non-final administrative decisions which may include disciplinary measures taken by the competent supervisory body responsible for the verification of the application of standards of professional ethics;
- decisions of the ECB, the EIB, the European Investment Fund or international organisations;
- decisions of the Commission relating to the infringement of the Union's competition rules or of a national competent authority relating to the infringement of Union or national competition law.
- decisions of exclusion by an authorising officer of an EU institution, of a European office or of an EU agency or body.
- where a person who is a member of the administrative, management or supervisory body of the applicant, or who has powers of representation, decision or control with regard to that applicant (this covers the company directors, members of the management or supervisory bodies, and cases where one person holds a majority of shares), is in one or more of the situations referred to in points (c) to (f) above.
- where a natural or legal person that assumes unlimited liability for the debts of that applicant is in one or more of the situations referred to in point (a) or (b) above.
If an applicant is in one of the situations of exclusion listed above, it should indicate the measures it has taken to remedy the exclusion situation, thus demonstrating its reliability. They may include e.g. technical, organisational and personnel measures to prevent further occurrence, compensation of damage or payment of fines. This does not apply for the situations referred in point (d) of this section.
In the cases provided in (c) to (f) above, in the absence of a final judgement or where applicable a final administrative decision, the National or Executive Agency may exclude an applicant provisionally from participating in a call for proposals where their participation would constitute a serious and imminent threat to the Union's financial interests.
If the action for which the applicant has submitted its proposal foresees particular provisions for the participation of affiliated entities, the same exclusion criteria apply to affiliated entities.
Rejection from this procedure and administrative sanctions (exclusion or financial penalty) may be imposed on applicants or affiliated entities where applicable, if any of the declarations or information provided as a condition for participating in this procedure prove to be false.
The National or Executive Agency may publish on its internet site the following information related to the exclusion and, where applicable, the financial penalty in the cases referred to in points (c), (d), (e) and (f) of the section above:
- the name of the applicant concerned;
- the exclusion situation;
- the duration of the exclusion and/or the amount of the financial penalty.
These exclusion criteria apply to applicants under all Actions of the Erasmus+ Programme. To certify that they are not in one of the situations mentioned above, applicants for an EU grant exceeding 60 000 EUR must provide a declaration on their honour certifying that they are not in any of the situations referred above. This declaration on honour constitutes a specific section or an annex of the application form.
In case of proposals submitted on behalf of a consortium of partners, the criteria described above apply to all participating organisations involved in the project.
In accordance with Articles from 106 to 109 of the EU Financial Regulation, administrative and financial penalties may be imposed on applicants who are guilty of misrepresentation or are found to have seriously failed to meet their contractual obligations under a previous grant award procedure1.
Furthermore, the Commission considers that for the implementation of Actions covered by the Programme Guide, the following organisations are or could be in a situation of conflict of interest and therefore are or could be not eligible to participate:
- National Authorities in charge of supervising National Agencies and the implementation of the Erasmus+ Programme in their country cannot apply or participate in any Action managed by National Agencies in any country, but may apply for participation (as applicants or partners) in Actions managed by the Executive Agency or by DG EAC unless that is explicitly excluded for the Action concerned (as indicated in Part B of the Guide);
- National Agencies (sole activity of their legal entity) or National Agencies departments of legal entities dealing with activities outside the remit of National Agencies cannot apply or participate in any Action implemented through this Guide;
- Structures and networks identified or designated in the Erasmus+ Programme or in any Annual Commission Work programme adopted for the implementation of the Erasmus+ Programme for specifically receiving a financial contribution from the Commission under the implementation of the Erasmus + Programme, which are hosted by the legal entity that also hosts the National Agency, cannot apply or participate in any Action managed by Erasmus + National Agencies in any country, but may apply for participation (as applicants or partners) in Actions managed by the Executive Agency or by DG EAC unless that is explicitly excluded for the Action concerned (as indicated in Part B of the Guide); they should be able to demonstrate, before being awarded a grant or a contract, that they are not in a conflict of interest either because precautionary measures are taken by them or because their internal organisation is such that there is a clear separation of interests. Furthermore, costs and revenues of each action or activity for which the EU funds are awarded must be identified. The decision for admitting there is sufficient assurance they are not in an actual conflict of interest is taken by the Executive Agency or by DG EAC, under their own responsibility and accountability, to which they apply;
- Legal entities hosting the Erasmus+ National Agencies but dealing with other activities inside or outside the remit of the Erasmus + Programme, as well as entities affiliated to these legal entities, cannot apply or participate in any Action managed by National Agencies in any country, but may in principle apply for participation in Actions managed by the Executive Agency or DG EAC unless that is explicitly excluded for the Action concerned (as indicated in Part B of the Guide). However, they have to demonstrate, before being awarded a grant or a contract, they are not in a conflict of interest either because precautionary measures are taken by them or because their internal organisation is such that there is a clear separation of interests.(e.g. a minimum separation of accounts, separation of reporting and decision making lines, measures to prevent access to privileged information). Furthermore, costs and revenues of each action or activity for which the EU funds are awarded must be identified. The decision for admitting there is sufficient assurance they are not in an actual conflict of interest is taken by the Institution, under their own responsibility and accountability, to which they apply.
Through the selection criteria, the National or Executive Agency assesses the applicant's financial and operational capacity to complete the proposed project.
Financial capacity means that the applicant has stable and sufficient sources of funding to maintain its activity throughout the period during which the project is being carried out or the year for which the grant is awarded and to participate in its funding.
The verification of the financial capacity does not apply to:
- public bodies2;
- international organisations.
In case of EU grant requests submitted by other types of organisations (i.e. other than those mentioned above) and not exceeding 60 000 EUR, applicants must provide a declaration on their honour certifying that they have the financial capacity to implement the project. This declaration on honour constitutes a specific section of the application form.
In case of EU grant requests submitted by other types of organisations and exceeding 60 000 EUR, the applicant must submit, in addition to the declaration on honour, the following documents through the Participant Portal:
- For Actions managed by the National Agencies: the applicant’s profit and loss account and the balance sheet for the last financial year for which accounts were closed;
- For Actions managed by the Executive Agency: a Financial Capacity Form filled in with the relevant statutory accounting figures and the financial statements (including the profit and loss account, the balance sheet, and other annexes if relevant) for the last two financial years for which accounts were closed;
- For entities which cannot provide the above documents because they are newly created, a financial declaration or an insurance declaration stating the applicant's professional risks may replace the above documents.
Organisations must upload these documents in the Participants Portal either at the time of their registration in the Portal (see section "Step1: Register in the Participants Portal" above) or by the deadline stipulated by the specific Erasmus+ action.
Following a risk-assessment carried out by the National Agency and in case of doubt on the financial capacity of any of the participating organisations involved in a project if the proposal is submitted on behalf of a consortium of partners, the same documents may be requested from the participating organisations by the National Agency or the Executive Agency, even if the granted amount is below the threshold of 60 000 EUR or if the cumulated granted amount to the same organisation exceeds the threshold of 60 000 EUR.
Where the application concerns grants for a project for which the amount exceeds 750 000 EUR, in addition to the above, an audit report produced by an approved external auditor may be requested. That report shall certify the accounts for the last financial year available.
If, following the analysis of these documents, the National or Executive Agency concludes that the required financial capacity has not been proved or is not satisfactory, then they may:
- ask for further information;
- offer a grant agreement or decision with a pre-financing covered by a financial guarantee3;
- offer a grant agreement or grant decision without pre-financing or with a reduced pre-financing;
- offer a grant agreement or grant decision with pre-financing based on several instalments;
- reject the application.
Operational capacity means that the applicant has the necessary professional competencies and qualifications to carry out the proposed project. Applicants must provide a declaration on their honour certifying that they have the operational capacity to implement the project. In addition, if required in the application form and if the grant exceeds 60 000 EUR, applicants may be asked to submit the CVs of the key persons involved in the project to demonstrate their relevant professional experience or other supporting documents such as:
- A list of relevant publications of the main team;
- An exhaustive list of previous projects and activities performed and connected to the policy field or to this specific action.
The award criteria allow the National or Executive Agency to evaluate the quality of the project proposals submitted in the framework of the Erasmus+ Programme.
Within the limits of the budget available for each Action, grants will be awarded to those projects which respond to these qualitative criteria in the best way.
The full set of award criteria applying to each of the Actions implemented through the Erasmus+ Programme Guide are described in Part B of the Guide.
- 1. Except for actions implemented by National Agencies
- 2. Including schools, higher education institutions and organisations in the fields of education, training, youth and sport that have received over 50 % of their annual revenue from public sources over the last two years shall be considered as having the necessary financial, professional and administrative capacity to carry out activities under the Programme.
- 3. The guarantee may be replaced by a joint guarantee, or from several guarantees from the participating organisations who are co-beneficiaires of the project.