Frequently asked questions
In the interest of the equal treatment of Applicants, the Managing Authority cannot give a prior opinion on the eligibility of an Applicant, a partner, a project or specific activities.
Questions that may be relevant to other Applicants, together with the answers, will be published in this section. It is therefore highly recommended to consult it regularly. Replies will be given within 10 days.
The Managing Authority cannot organise individual consultations with Applicants or partners following the principle of equal treatment. Public events on the call will be announced on the Programme website.
In order to view the answers to your questions, please check on a regular basis the tab “Answers" of your account the Programme website.
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1. General information on the call for strategic projects
1.1 Can a project focus on more than one Priority? Published on 16.04.2019
NO, according to paragraph 4.4.1 of the Guidelines for Applicants, a proposal can only address one Thematic Objective and one Priority even if there may be cross-over effects with other Priorities. The e-Application Form will not allow to choose more than ONE priority.
1.2 Is there any limitation on the number of proposals that can be submitted by the same Applicant? Published on 16.04.2019
Yes. According to paragraph 4.4.1 of the Guidelines for Applicants, the same organisation can participate only once as an Applicant under each Priority. This means, for example, that one University (despite the functional independence of its departments) will be able to submit, as Applicant, ONLY one project proposal for each of the eleven priorities of this first call for proposal. No limitation in the number of proposals is foreseen if the one organization participates as a partner.
1.3 What does the word “organisation” mean in order to verify the respect of the limit in the number of project proposals that can be submitted? Published on 16.04.2019
The limitation on the number of applications that the same organization can submit as Applicant is one for each of the 7 Priorities of the call. Paragraph 4.4.1 of the Guidelines for Applicants, footnote n. 16, clarifies the meaning of organization, which is: “Any legal entity, […] that according to the national legislations […], is provided with juridical, economic, technical and human capacities committed by a legal person as a whole. These conditions must result from supporting documents (such as statutes, registration papers and/or other official documents) proving the capacity to undertake legal obligations (signing contracts), to assume financial liability and to manage the resources for the achievement of stated purposes (i.e. Public administrations or Universities will be considered as ONE organisation represented by ONLY ONE legal person despite the functional independence of their departments or units). The participation of each organisation will be checked under step 1 (relevance and quality of the design) on the basis, among other things, of the following information: national registration number (e.g. VAT, national code, social security, etc.), name of the organisation and name of the legal representative".
1.4 Can the same organisation participate as a partner in two projects proposals focusing on the same priority? Published on 16.04.2019
Yes. There is no limitation in the number of proposals where the same organization can participate as partner.
1.5 If the same applicant submits 7 proposals (one per each priority), what is the maximum number of grants that can be awarded as Lead Beneficiary? Published on 16.04.2019
According to section 4.4.1 of the Guidelines for Applicants, an Applicant cannot be awarded more than three grants as Lead Beneficiary under this call for proposals. In case more than two proposals from the same Applicant are preselected according to the rules if this call, only the two best-ranked proposals will be included in the list of projects recommended for funding. This rule does not apply to partners meaning that the same partner could be involved in more than two projects that have been awarded a grant.
1.6 Do the project, financial and communication managers have to be part of the staff of the Applicant or could they be sub-contracted? Can these roles be assigned to partners? Published on 16.04.2019
As per section 2.5 of the Guidelines for Applicants, in order to guarantee a good management of the project and as a minimum requirement, the following project management positions shall be ensured by the Applicant: a project coordinator, a financial manager, and a communication manager. These key staff members should be preferably part of the permanent staff of the Lead Beneficiary. Moreover, since the overall management is considered the main responsibility of the Lead Beneficiary, the whole project management cannot be sub-contracted. This means that the overall coordination shall always remain under the responsibility of the Lead Beneficiary organization that can be supported by external experts. Despite these three main roles shall be ensured by the Applicant, this does not mean that partners cannot be involved in these activities.
1.7 Can two or more different organisations be involved as one single partner in a project proposal? Published on 16.04.2019
No. As stated in footnote n.16 of the Guidelines for Applicants which defines the meaning of organisation, the participation of "each organisation will be checked under step 1 (relevance and quality of the design) on the basis, among other things, of the following information: national registration number (e.g. VAT, national code, social security etc.), name of the organisation and name of the legal representative".
1.8 Will there be a pre-assessment of project ideas? Published on 16.04.2019
No, the project ideas will not be assessed by the Managing Authority (MA). In fact, in the interest of equal treatment of Applicants, the MA cannot give a prior opinion on the eligibility of an Applicant, a partner, a project or specific activities.
1.9 What is the duration set for project proposals under this first call for standard projects? Published on 16.04.2019
According to paragraph 4.4.4 of the Guidelines for Applicants, the duration of project proposals shall not be lower than 24 months and must not exceed 30 months. According to article 18.3 of the “COMMISSION IMPLEMENTING REGULATION (EU) No 897/2014 of 18 August 2014 laying down specific provisions for the implementation of cross-border cooperation programmes financed under Regulation (EU) No 232/2014 of the European Parliament and the Council establishing a European Neighbourhood Instrument”, all project activities financed by the programme shall end on 31 December 2022 at the latest.
1.10 Where can I can find the list of National Contact Points? Published on 16.04.2019
The updated list of National Contact Points can be downloaded here: http://enicbcmed.eu/contacts.
1.11 What happens if, at the time of the submission of the supporting documents, there have been some changes in the name, registration number or legal representative of an institution as indicated in the e-Application Form? Published on 16.04.2019
Changes such as the name of the legal representative or in some cases registration number due for example to the merge of an institution with a pre-existing one are allowed provided that these are fully explained through the supporting documents to be sent for the verification of eligibility. In particular, the supporting documents will have to prove that the institution indicated in the e-Application Form has not changed and justify the modifications regarding the above-mentioned elements. Therefore, copies of a new law, for example, that explains the merge of an institution with another one etc., must be provided. All changes should be indicated in a letter addressed to the MA attached to the supporting documents to be sent within the deadline specified by the MA in the notification letter addressed to the Applicant of the projects admitted to step 2 of the evaluation process.
2. Eligibility of Applicant and partners
2.1 Can the Managing Authority (MA) give a prior opinion on the eligibility of the Applicants and partners if supporting documents are sent in advance? Published on 15.04.2019
No, the MA cannot give a prior opinion on these issues since they will be examined during the verification of eligibility. If further information is needed on the eligibility of an organisation involved in a project, the MA will send a request for clarification to the Applicant.
2.2 In which case the Applicant organisation shall provide the external audit report foreseen in section 5.4.2 of the Guidelines for Applicants in order to certify its accounts for the last two financial years available? Published on 17.04.2019
The obligation to provide an external audit report applies to Applicants and partners but it does not concern public administrations, public bodies and international organisations. In the report, the data concerning the financial capacity (i.e. for companies the total annual income, net income - profit and loss - own funds and total liabilities) have to be pointed out and/or highlighted (see par. 5.4.2 of the Guidelines for Applicants).
2.3 Can a person from a different department of the same organization participating as partner in a project, receive per diem and travels compensation as an associate? Published on 17.04.2019
Provided that the MA cannot give a prior opinion on specific issues concerning the appointment of project staff that remains a decision of the organization participating in the project, associates should be considered as organisations represented by one or more persons that can be invited to attend meetings or events. In particular, associates cannot manage any project budget but their travel and subsistence costs can be covered by the Applicant or a partner, provided that these costs have been included in the budget (the number of travels should be included within the travel and per diem cost category).
2.4 Can an associate participate in tender procedures launched by the Beneficiary/partners or be awarded a sub-grant? Published on 17.04.2019
No. As per section 4.3.2 of the Guidelines for Applicants, “associates play a real role in the project but cannot receive funding from the grant”. Therefore, the role of the associate is not compatible with that of sub-contractor or that of organization being awarded a sub-grant.
2.5 Should the Applicant be audited before submitting a project proposal? Published on 17.04.2019
As per section 5.4.2 "Verification of the eligibility of Applicant and Partner organisations" of the Guidelines for Applicants, both Applicants and partners shall submit an external audit official report made by chartered auditors of the partners’ annual accounts for the last 2 financial years, if available. Those entities which are not requested by the national law to produce such official annual reports will have to provide the annual accounts for the last 2 financial years signed by the legal representative.
2.6 Can one organisation participate in the same project with more departments/units? Published on 16.04.2019
No. As stated in the Guidelines for Grant Applicants (see par. 4.4.1 footnote n. 16), “One organisation can be represented by ONLY ONE legal person despite the functional independence of its departments or units”. The same organisation - with one legal representative and one single registration number - cannot be represented more than once within the same project.
2.7 Are international organisations eligible under this call for standard projects? Updated on 17.04.2019
International organisations can participate in this call following the rules set in section 4.3.2 of the Guidelines for Applicants, in particular:
- pursuant to Article 43 of the Implementing Rules of the Financial Regulation for the General Budget of the European Union, international organisation means international public-sector organisations set up by intergovernmental agreements, and specialised agencies set up by such organisations
- these organisations may have a worldwide or regional scope. Organisations created under national law are not international organisations (e.g. national NGO with several regional/country offices); - international organisations can participate only if they have an agreement with the government of the country in which they are going to carry out project activities;
- international organisations can participate as Applicants or Partners only if they have an operational office in the eligible area (see section 4.3.2 of the Guidelines for Applicants). The said office must have the capacity to undertake legal obligations (signing contracts) and assume financial liability.
Finally, international organisations cannot be taken into consideration in calculating the minimum number of countries within a partnership. As far as the 50% rule is concerned, if an international organisation is based in a Mediterranean partner Country (MPC), its direct costs will be calculated as part of funds managed by MPCs.
2.8 Can companies from the same group (mother company and subsidiaries based in other countries or in the same country) participate as two different partners within the same proposal, even if they have different VAT numbers? Published on 17.04.2019
The principle is that only legal entities can participate. Therefore, if a branch office is registered as a separate legal entity in a country different than the head office, it can be considered as a partner coming from that country. As a minimum requirement, a partnership shall represent 3 different eligible countries, of which at least one EU country and one Mediterranean Partner Country. However, situations, whereby this minimum requirement is satisfied for example by a partnership including the head office from Italy and branch offices from Lebanon and Egypt, should be avoided. Therefore, a partnership should comprise other eligible partners alongside with the branch offices if they participate in the project.
2.9 Where can I find the list of eligible and adjoining regions? Published on 16.04.2019
The list of eligible regions is available in section 4.1 of the Guidelines for Applicants. As per section 4.3.1 of the Guidelines, Applicants cannot come from adjoining regions.
2.10 Is it possible for a university researcher to take part in a project as an independent member of a research team? Published on 17.04.2019
As a rule, the participation in the call for strategic projects is only open to legal persons (i.e. organisations). Since natural persons are not mentioned in the Joint Operational Programme, they are not allowed to participate in calls for proposals as applicant or partner (see par. 4.3.2 of the Guidelines for Applicants, footnote n. 12).
2.11 Can partners from regions adjoining to the eligible ones participate in the call for proposals? Published on 17.04.2019
Yes. According to the Joint Operational Programme (section 1.1.2) and to the Guidelines for Applicants (section 4.3.1 and 4.3.2), participation of partners located in adjoining regions listed in section 4.1 may be allowed by the Joint Monitoring Committee on a case by case basis, taken into account the objective benefits that such participation would ensure a specific project and to the Programme as a whole. Adjoining regions contribute to the fulfilment of the minimum partnership requirement, i.e. at least 4 different countries including at least two EU Mediterranean Countries and two Mediterranean Partner Countries. In any case, the amount of resources allocated to partners from adjoining regions, as listed in paragraph 4.3.1 of the Guidelines for Applicants, should not exceed 20% of the total direct budgeted costs of the project. The Applicant (Beneficiary) cannot come from an adjoining region.
2.12 What are the eligibility criteria concerning the legal status of Applicants and partners? Published on 17.04.2019
The eligibility criteria concerning the legal status of an organisation are defined in the Guidelines for Applicants (section 4.3.2). A “non-exhaustive” list is also contained in footnote n. 13 of the Guidelines for Applicants. Please note that since natural persons are not mentioned in the Joint Operational Programme, they are not allowed to participate in calls for proposals as Applicant or partner (see footnote n. 13 of the Guidelines for Applicants). As a consequence, only legal entities established in accordance with national legislation, laws and regulations can participate in calls for proposals. Please note that it is in the interest of the Applicant and of the whole partnership to know the correct legal status of an organization, since this is relevant to determine the financial capacity.
2.13 Is the participation of an adjoining region to a project linked to that of an eligible region? Published on17.04.2019
The participation of adjoining regions is allowed at Programme level: it means that they can be involved in a project independently of the participation of eligible regions. The MA reminds that the participation of adjoining regions may be allowed by the Joint Monitoring Committee (JMC) on a case by case basis, taking into account the objective benefits that such participation would ensure to a specific project and to the Programme as a whole. Therefore, in order to enable the JMC to decide on this issue, the project should clearly describe and justify in the Application Form the added value that the partner coming from an adjoining region would bring to the achievement of project expected results.
2.14 Are there any geographical limitations concerning the Applicant and partners? Published on 17.04.2019
According to section 4.3.1 of the Guidelines, the Applicant and partners shall come from one of the eligible regions of the countries participating in the Programme. The Applicant cannot come from an adjoining region.
2.15 Is it possible to implement activities outside the Programme eligible area? Published on 17.04.2019
As a rule, all activities financed in the framework of the project should be implemented inside the Programme eligible area or in the relevant adjoining regions, if the participation of partners from those regions is allowed (see section 4.3.1 of the Guidelines for Applicants). This means that an event organised for instance in Germany or Ukraine is not eligible.
2.16 Is there a recommended number of partners to be involved in a project? Published on 17.04.2019
There is no specific requirement concerning the maximum number of partners to be involved in a project since this depends on the objectives of the activities and results to be achieved. However, to ensure smooth management of a project, the Joint Operational Programme (see paragraph 4.4) foresees that for standard projects, the maximum recommended number of organizations to be involved in a partnership is 10 (meaning the Applicant and 9 partners).
2.17 Is there a minimum number of organizations to be involved in a partnership? Published on 17.04.2019
According to the Guidelines for Applicants, the minimum number of countries to be represented in a partnership is 4 (including two EU Mediterranean Countries and two Mediterranean Partner Countries).
2.18 Is it possible to implement activities in an eligible territory from which no organisation is represented in the partnership? Published on 17.04.2019
Despite not recommended, there is no formal requirement that the location of activities must be restricted to the eligible regions of the countries where the Applicant and partners are registered. However, this must be clearly mentioned in the description of the project activities, together with the methodology and the reason why the project wants to implement activities in an eligible region not represented in the partnership.
2.19 Is it possible to participate in events organised by third parties outside the Programme eligible area? Published on 17.04.2019
In this case, the location of the event is something the Lead Beneficiary and partners cannot influence. As long as the participation in such events (seminars, training, conferences, study trips, etc.) is relevant to the rationale of the project and is essential to achieve its objectives, it could be considered as eligible for financing (such participation will, however, have to be duly justified in the Application Form).
2.20 Can a partnership include more than one organization from the same country? Published on 17.04.2019
Yes, provided that the minimum partnership criterion is fulfilled (at least three different countries, representing at least one EU Mediterranean Country and one Mediterranean Partner Country). However, please note that according to paragraph 4.4. of the Joint Operational Programme (and paragraph 4.4.2 of the Guidelines for Applicants) the partnership shall not include more than three organisations from the same country.
2.21 What are the geographical rules applying to associates? Published on 17.04.2019
Associates do not have to meet the criteria set in section 4.3.1 of the Guidelines for Applicants on geographical eligibility. This means that associates may also be established in countries other than those eligible under the Programme. Associates are not partners. Therefore, they cannot, in any case, contribute to reaching the minimum partnership requirement. They may not receive Programme funding. They can attend project meetings and events and their subsistence (per diem) and travel costs will be paid by the Beneficiary or by one or more of the partners. In the event they want to play a role in the implementation of the project activities, a description of their tasks will have to be included in the Application Form: this will be assessed during project evaluation, provided that associates have to implement the activities at their own costs. There is no maximum number of associates, however, all of them must sign the Associated Partner Declaration to be uploaded in the E-Application Form and they should also sign a memorandum of understanding with the Beneficiary and partners in order to define their exact role as well as who will pay for their subsistence and travel costs. Associates do not need to sign the Partnership Agreement (compulsory only for the Beneficiary and project partners).
2.22 Can an Applicant or partner having its headquarter out of the eligible territories but only a decentralised office in the eligible regions submit a project proposal? Published on 17.04.2019
Yes, the participation of Applicants and partners not having their main headquarter but only a decentralised registered office or structure in the eligible regions is admitted. The said structure must have the capacity to undertake legal obligations (meaning that there must be a responsible person of this office who is independent in terms of being able to launch call for tenders, recruit temporary staff and sign contracts) and assume financial liability (for example the said person shall be able to sign payment orders referred to the contracts signed with contractors, etc.), provided that this office has been established for at least 2 years before the deadline set for the submission of the Application Form. These conditions must be proved by supporting documents (such as statutes, registration papers and/or other official documents). The supporting documents shall be provided only upon request of the MA as foreseen by section 5.4.2 of the Guidelines for Applicants. Since the possibility to comply with the above-mentioned conditions may vary depending on the national legislation, in case of doubt please refer to the concerned National Contact Point.
2.23 Can a Ministry or a National Authority located out of the eligible territories take part in a project? Published on 17.04.2019
Yes, according to paragraph 4.3.1 of the Guidelines for Applicants, Ministries or National Public Administrations located in non-eligible areas of the participating countries can participate, as Applicant or partner, if not represented locally in the eligible areas or if they have a local office that cannot take legal or financial obligations, provided that they can demonstrate that the activities will be carried out in and for the full benefit of the eligible regions of the Programme. In case a Ministry or a National Authority is represented at the local level in an eligible territory, the project activities should be implemented by the local structure. During the verification of the eligibility within the evaluation process, the MA may require proof of the territorial competence of the institution.
2.24 What are the main rules concerning sub-grants? Published on 17.04.2019
According to paragraph 4.5.6 of the Guidelines for Applicants, sub-grants may be awarded by the Beneficiary or partners to offer financial support to third parties (including physical persons) to be involved in carrying out some specific project activities. Sub-grantees have to be resident or established in the Programme eligible area of the participating countries of the Applicant and partners. They should be duly justified and compliant with the State Aid provisions (de minimis regime) as referred in paragraph 5.6 of the Guidelines. Moreover, according to paragraph 4.4 of the Joint Operational Programme, there are some financial limitations that apply to sub-grants:
- a maximum of amount of €60.000 can be given to each third party;
- maximum of 30% of the total direct costs of a project can be awarded as sub-grants. The amount of project direct costs to be sub-granted must be included in the Budget heading “Other costs”.
Finally, the Applicant will have to provide information on how the sub-grant procedures will be managed, on the selection criteria the indicative number of sub-grants to be awarded, the final beneficiaries and the expected impact of the sub-grants. The Programme does not foresee any specific requirement to select sub-grantees. Since sub-grandees need to be selected, their names cannot be identified a priori in the application form.
2.25 Do sub-contractors have to be established in territories eligible under the Programme? Published on 17.04.2019
Participation in the award of procurement contracts is regulated by rules on nationality and origin set out in articles 8 and 9 of Regulation (EU) No 236/2014. As far as the rule of nationality of the sub-contractors is concerned, there is no specific geographical restriction according to article 15 of the Grant Contract.
2.26 Can an organization based in the Lisbon area be the Applicant of a project under the Thematic Objective "A.3 Promotion of social inclusion and the fight against poverty"? Published on 17.04.2019
The participation of organisations from the Lisbon area is allowed (as Applicant and partners) under all the seven Priorities of the three Thematic Objectives (A.1, A.2 and A.3) within the Overarching Objective 1. Please note that only Priorities A.1.1, A.1.2, A.2.1 and A.3.1 are covered by the call for strategic projects.
2.27 Is there a list of the entities that are included in the category "Body governed by public law" as defined by Directive 2014/24/EU? Published on 17.04.2019
There is no pre-defined list so Applicants and partners shall refer to the criteria mentioned by the EU Directive reported in par. 4.3.2 of the Guidelines for Applicants. Since the inclusion under this category may depend also from national legislations, in case of doubts please contact the respective National Contact Point of the concerned participating country.
3. Budget and eligible costs
4. Application form