Q : Are there any obstacles to consider as eligible the preparatory costs referred to in article 48.4 of the ENI CBC Implementing Rules, which will be incurred before the entry into force of the relevant Financing Agreement?

Q : In accordance with Article 48.4 of the ENI CBC Implementing Rules, costs incurred by the projects before the submission of the grant application, linked to the preparation of strong partnerships, are eligible provided that the conditions listed are met.
According to EC’s understanding, and applying mutatis mutandis the above provisions, the preparatory costs incurred by the beneficiaries for projects awarded without a call for proposals (which is the case for the majority of LIPs) shall be eligible as of the date of adoption of the programme by the Commission.
There is no link between the provisions in Article 48.4 and the entry into force of the Financing Agreements, so programmes should set no restrictions to the eligibility for preparatory costs both in MS and CBC Partner Countries (subject to their judgment and under their responsibility).