The partners of the ETC-programme INTERREG Germany-Netherlands would like to formulate a first approach to the debate on simplification within the ‚High Level Group on Simplification’ as follows:  

The partners have discovered that a lot of administrative burden for beneficiaries is due to national rules – especially concerning matters where there is a lack of clear EU rules. An example is the provision of all original supporting documents for every first- or second level control. Nevertheless, the partners agree that there is an urgent need for further simplification of the EU rules for ETC programmes. The separate treatment of ETC programmes from other EU funded programmes is welcomed and needs to be enhanced in the future, due to the specific character of the cooperation within INTERREG. The ETC regulation 1299/2013 has been a step into the right direction. However, many other regulations, delegated/implementing acts and guidance apply to all programmes and lead to a considerable administrative burden in the ETC field.  As an example, the new procedures for the management and control systems and for the designation of authorities have led – and are still leading - to a great administrative burden and much effort for the authorities involved, although the management and control systems have hardly changed in comparison to the INTERREG IV programme. 

For the efficient use of the ETC funds, a general exemption of INTERREG-programmes in the area of state aid would be desirable. A 100% of the funds in INTERREG is used for cooperation projects whose distortionary effects on the market are very low to non-existent. However, the necessary controls for state aid constitute a very high administrative burden. The addition of art. 20 of the GBER is very much welcomed, but only led to a small decrease of the total necessary effort.   

In more detail, our INTERREG-programme foresees difficulties due to the deadlines regarding the annual accounts – our audit authority is expecting a time problem (between the last payment claim of the period until 31st July and handing in the documents on February 15). In addition, the integration of the fraud prevention measures (following art. 125 and guidelines ‘Fraud Risk Assessment and Effective and Proportionate Anti-Fraud Measures, of June 2014) into the already existing national measures for fraud prevention is causing a lot of effort; the self-assessment does not match the existing systems.

We hope that we can herewith contribute to a more efficient management and administration of INTERREG-programmes in the future and are happy to provide more detailed information and further ideas.

The Partners of INTERREG Germany-Netherlands (www.deutschland-nederland.eu)