Q. Which should be the interpretation of articles 32.2 and 26.6 of the ENI CBC IR? Should the Managing Authority verify each payment claim by re-performing the work of the external auditors? Or is it possible that such re-performance may be done on the sample of projects selected for the on-the-spot checks?

A. The ENI CBC IR do not give any detail on the scope of the “administrative verifications”. The Managing Authority should make a compliance check of each payment request, such as:

• verifying that all requested documents are present, complete and compliant with the requirements in the grant contract, both content-wise and format-wise (financial report, technical report and expenditure verification report),
• checking that the key amounts are in conformity with the grant contract (total budget, amount of pre-financing received, etc.),
• checking that the documents are signed by the legal representative.

The Managing Authority should perform this type of administrative verifications for each payment request, so that the requirement in article 26(6) is followed. A check-list for the verification of each payment request carried out should be filled-in by the Managing Authority and shall serve as evidence of the work done.

In addition, further controls can be carried out when receiving the payment request, aiming at ensuring the reliability of the expenditure verification reports. This is particularly important when the document review raises doubts about the eligibility of part or all of the declared expenditure. Further controls can be done as part of the quality control of a sample of documents, an on-the-spot check and/or at any other moment (e.g., due to an alert by the National Authority or Control Contact Point) and may imply requesting the submission by beneficiaries of supporting documents for the expenses in question.

The ENI CBC IR do not require the Managing Authority or the Joint Technical Secretariat to re-perform the expenditure verification of all supporting documents for all expenses declared in each payment request; otherwise, the work of the auditors would be void. However, the Managing Authority and the Joint Technical Secretariat must obtain an assurance that the expenditure verification is done in the required quality, and, in general, that all required elements are in place before a payment is done.