Questions and answers

As per PRAG, in the interest of equal treatment of Applicants, the Joint 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, are published in this section. It is therefore highly recommended to regularly consult it.

Inquiries may be sent in English or French to the following email: enpi.strategic@regione.sardegna.it. Answers will be given within 10 days.

Questions may be sent no later than 15 calendar days before the deadline for the submission of the proposals. Replies will be given no later than 7 calendar days before the deadline.

The Joint Managing Authority cannot in any case organise individual consultations with Applicants following the principle of equal treatment. Any public event will be announced on the Programme website.

1. General information on the Call for Strategic projects (ToRs and general rules)

Yes, however the Applicant shall collect the original handwritten signed originals and send them upon request of the JMA.

In order to prove that the person is/was entitled to sign on behalf of the organisation, the concerned Applicant or partner must send, as supporting documents within the 22nd of March 2012, both the documents related to person indicated in the Concept Note and those related to the new legal representative (i.e. statutes of the organisation containing the description of the powers of the legal representative to sign contracts, together with a copy of the decision of the board of directors appointing the legal representative, etc. ). Public bodies created by a law should send copy of the law that describes which position is entitled to legally and financially represent the organisation and a copy of the decree that nominates the legal representative. The JMA may also request clarification to the Applicant if the documents provided do not clearly demonstrate the fulfilment of the eligibility criteria.

Changes such as 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, provided that no changes in the partnership composition are allowed, the supporting documents will have to prove that the institution indicated in the Concept Note 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 JMA attached to the documents to be sent with the Full Application Form by the 6th of February.
Please note that the supporting documents related to these changes must be sent within the March, 22nd together with those related to the verification of the eligibility of the Applicant and partners.

Yes, the maximum number of work packages is 8, while the minimum is 4 (Project Management, Communication, Capitalisation and at least one where project activities are described).

According to the Guidelines for Applicant the main elements of the Concept Note cannot be changed in the Full Application Form. However the list of the areas can be better specified or modified taking into consideration “questions and answers” n.2.2; 2.3 and 2.4 All changes will have to be justified.

Yes. In case the Applicant requested each partner to send the Partnership Statement signed before the opening of the second stage, the JMA will accept this document. However given to the fact that in the Partnership Statement the partner declares that it has fully read the Full Application Form and fully understood its role within the project, Applicants are invited to make sure that the final version of the Grant Application Form is sent to all partners.

Provided that the duration of projects submitted under the ongoing call for strategic projects cannot be lower than 24 months and it cannot exceed 36 months, the duration originally foreseen can be increased or decreased taking into consideration that the timeframe must guarantee the achievement of the expected results and a logically planned implementation of the activities. If the project duration changes from the Concept Note to the Full Application Form, this change must be justified in the description of the methodology.

The declaration for International Organisation has to be provided only upon explicit request of the JMA. It will be requested as supporting document in case the Concept Note is preselected, i.e. this declaration shall not be provided for the Concept Note stage.

First of all, the verification of eligibility will be performed only for projects whose Concept Notes have been preselected and which have been invited to submit a Full Application Form. In this case, Applicants will be given 45 calendar days, in addition to the 45 calendar days to submit the Full Application Form, to provide the supporting documents.
The list of supporting documents can be consulted in section 4.2.4 of the Guidelines for Applicants. This list is not exhaustive since copies of other official documents may be provided to prove the eligibility of the Applicant and its partners (such as internal acts empowering the legal representative to sign, decision of the management board, etc.).

As per section 2.4 of the Guidelines for Applicants, in order to guarantee a good management of the project, the Beneficiary shall appoint as a minimum requirement a project coordinator, a financial manager and a communication manager. This does not exclude that partners are involved in these activities.

Section 4.5 of the Guidelines for Applicants contains an indicative calendar of the whole selection procedure. The timeline will depend on the actual number of Concept Notes submitted. Following this calendar, the notification to successful concept notes to submit Full Application Forms is expected around 120 calendar days after the deadline for the submission of the Concept Notes. The JMA will inform regularly on the Programme website on the state of play of the evaluation process.

According to section 4.2.1 of the Guidelines for Grant Applicants, the Programme will preselect, in accordance to the ranking list, those Concept Notes whose sum of requested contributions amounts to at least twice the available budget for this call for proposals, taking into account the indicative financial envelopes foreseen for each Priority (about € 37.440.000 for Priority 1 and € 24.960.000 for Priority 2).
The highest ranked Full Application Forms will then be provisionally selected for the award of a grant taking into consideration this financial allocation per Priority.

According to section 3.1.2 of the Guidelines for Applicants, an Applicant may not be awarded more than two grants under this Call for Proposals. Therefore in case more than 2 proposals (only possible for two different topics according to the rule limiting the participation as Applicant - see question n. 1.3) from the same Applicant are preselected, only the 2 best ranked proposals will be retained in the list of recommended projects to be financed.
This rules does not apply to partners meaning that the same partner could be involved in more than two projects that have been awarded a grant.

Yes. As the limitation for participation applies at topic level (see question 1.3 for more information), it is possible to participate as partner in two different projects focusing on the same specific objective within one topic.

According to European Commission Recommendation 2003/361/EC concerning the definition of micro, small and medium-sized enterprises, SMEs can be identified based on the following criteria:
- Headcount: < 250 for Medium-sized enterprises and < 50 for Small-sized enterprises;
- Annual turnover: ≤ € 50 million for Medium-sized enterprises and ≤ € 10 million for Small-sized enterprises.
Moreover, following the EC definition, an enterprise is “any entity engaged in an economic activity, irrespective of its legal form”.
This definition of SMEs only concerns European Union Member States and does not preclude other definitions according to the national legislations of Mediterranean Partner Countries.

Expected results are considered as indicative suggestions in order to achieve the addressed specific objective. Proposals might consider them all or even only one. Projects can also introduce different expected results that might best contribute to the achievement of the mandatory specific objective explaining this choice.

The definition available in the Glossary provides also a dimension of clusters by sector. In fact, beside the geographical proximity it is stated "and associated institutions in a particular field, linked by commonalities and complementarities".

The specific objectives of each logical framework are directly linked to the general objective as a contribution to the achievement of the general objective. The logical framework shall therefore be analyzed in a horizontal way. The same approach applies to the expected results that are linked to each specific objective.

Capitalisation should refer to concrete activities implemented within the project timeframe and aimed at the identification, organisation and enhancement of experiences, knowhow or operational results. Moreover in the Full Application Form it is foreseen as mandatory a work package on the capitalization that will have to indicate how the project intends to capitalize its results.

Synergies should refer to ongoing projects, plans, programmes and have a clear territorial dimension (local, regional, national and/or cross border). All possibilities are open in order to demonstrate potential synergies with other initiatives. However, these will be evaluated considering how clearly they are defined.

According to a recent revision of article 43 of the Commission Regulation (EC) No 951/2007 of 9 August 2007 laying down implementing rules for cross-border cooperation programmes, the eligibility period for projects activities is extended until 31 December 2015.

As a consequence, the maximum duration of project proposals that will be submitted under the ongoing call for strategic projects might be up to 36 months.

This notification is compliant with the provision of footnote number 10 of the Guidelines for Grant Applicants “the duration up to 36 months is conditional to the notification of the extension of the eligibility period to 31 December 2015 by the European Commission; Applicants will be informed accordingly through the programme web site”.

NO, according to paragraphs 4.1.1 and 4.1.5 the partnership indicated in the Concept Note must remain unchanged in the Full Application Form (see also point 11 of the Full Application Form Check Grid). This means that if the partnership changes between the evaluation of the Concept Note and the submission of the Full Application Form, the project will be rejected since the relevance of the partnership is assessed only at stage 1 (Concept Note evaluation) and the score is reported to the evaluation grid of stage 2 (Full Application Form evaluation).

The provisions set in Annex IV shall be applied by all types of entities, except for public administrations of EU Member States and international organisations as mentioned in article 8 of the said annex. Private companies, for instance, must follow the procurement rules of Annex IV regardless they are located in an EU Member State or a Mediterranean Partner Country.

The JMA will request the documents to be sent for stage 2 only to the successful Applicants that pass stage 1 (concept note evaluation). In particular the JMA will request the submission of the following documents within 45 calendar days from the date of notification:

a) the full Application Form;
b) the Declaration by the Applicant for Full Application Form;
c) the partnership Statements for all partners involved.

Moreover the JMA will give additional 45 calendar days to submit the documents needed for the verification of the eligibility (such as statutes, financial identification form). In particular the JMA will specify, in the same letter of notification of the results of stage 1 which of the documents listed in par. 4.2.4 of the Guidelines for Applicants have to be submitted.

For stage 1 Applicants should submit only:
a) the Concept Note;
b) the Declaration by the Applicant for Concept Note duly filled in and originally hand written signed and stamped.
No, additional documents (other than those mentioned above) shall be attached to the Concept Note when submitting a proposal.

As per PRAG, in the interest of equal treatment of Applicants, the Joint Managing Authority cannot give a prior opinion on the eligibility of an Applicant, a partner, a project or specific activities.
Moreover, this call for proposals is a restricted procedure consisting in the submission of a Concept Note first and then, if the project proposal has been selected, a full Application Form.

NO, according to paragraph 3.2.1 of the Guidelines for Applicants, an application shall address only one specific objective within the selected topic and consider the relevant expected results and indicators listed within the concerned table described in paragraph 2.1

NO, according to paragraph 3.2.1 of the Guidelines for Applicants, an application shall be submitted in the framework of one single Priority and one single Topic within the chosen priority even if there are cross-over effects. Applications that do not clearly refer to one topic will be rejected.

According to paragraph 3.2.1 of the Guidelines for Applicants, foot note n. 11, the meaning of “organisation” is:

Any legal entity indicated under article 14 of the Regulation (EC) No. 1638/2006 (ENPI Regulation) and according to the national legislations of Mediterranean Partner Countries, which is provided with juridical, economic, technical and human capacities committed by the 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 stage 1 (Concept Note) on the basis of its national registration number (e.g. VAT, national code, social security etc.).

Yes. According to paragraph 3.2.1 of the Guidelines for Applicants, one Organisation can choose to participate per each topic according to two different options:
1) ONCE as Applicant

Or

2) Twice as partner.

This means, for example, that if one University wants to submit a project as Applicant on the topic “solar energy”, it will be able to submit ONLY one project proposal without having the possibility to participate in other projects on “solar energy” as partner.

Applications must be sent within July, 14th 2011.
Following the text of the call for proposals, Concept Notes are considered valid if submitted within the fixed deadline as evidenced by the date of dispatch, the postmark or the date of the deposit slip. In the case of hand-deliveries, the deadline for receipt is at 4:00 p.m. local time (Italy) as evidenced by the signed and dated receipt. Any Concept Note submitted after the deadline will automatically be rejected.
Moreover, for reasons of administrative efficiency, the Joint Managing Authority will reject any Concept Note submitted within the said deadline but received after the effective date of approval of the evaluation report step 1 by the Projects Selection Committee (as indicated in section 4.1.3 of the Guidelines for Applicants).

The JMA is located in Cagliari, within the Autonomous Region of Sardinia. Please refer to the "Contacts" section of this website for all relevant details.

2. Eligibility of Applicant and Partners (geographical and technical eligibility)

The obligation to provide an external audit report only applies to Applicants and not to partners and it does not concern public administrations, public bodies and international organisations. In case the Applicant does not usually certify its accounts, it shall indicate in section 2.3.2 of the Full Application Form the references of the external auditor that will perform the audit of its accounts for the last financial year available if the project is pre-selected. This certification will be requested by the JMA as supporting document during the verification of eligibility (step 3 of the evaluation process).

No, according to PRAG rules the JMA cannot give a prior opinion on these issues that will be examined during the verification of eligibility. If further information is needed on the eligibility of an organisation involved in a project, the JMA will send a request for clarification to the Applicant.

Provided that the JMA 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 organizations 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 per diem can be covered by the Applicant or a partner, provided that these costs are specified in the budget (under a specific line within the travel ad per diem cost category. See budget instructions for more details).

No. As per section 3.1.2 of the Guidelines for Applicants, “associates play a real role in the project but may not receive funding from the grant with the exception of per diem or travel costs”.
Therefore, the role of associate is not compatible with that of sub-contractor or that of organization being awarded a sub-grant.

Section 4.1.5 of the Guidelines for Applicants states that "the elements assessed on the basis of the Concept Note (partnership composition, specific objective and expected results) may not be modified by the Applicant in the Full Application Form". The composition of the partnership shall be interpreted based on the role played by each organisation in the project. In fact the responsibilities of the Applicant are clearly defined in the Guidelines (section 2.3): the Applicant bears legal responsibility and liability for the whole partnership vis-à-vis the Joint Managing Authority and among others submits the Application Form (Concept Note and Full Application Form) on behalf of the partnership. This is the reason why the Applicant must sign and submit since the Concept Note stage the Declaration by the Applicant in which its tasks and responsibilities towards the JMA are listed. Moreover according to the provisions set in section 3.2.1 of the Guidelines concerning the maximum number of proposals in which one organisation can participate, the limitation applies on the basis of the role played by an organization within a project (i.e. for each topic one proposal as Applicant or twice as partner).
Finally according to the qualitative evaluation grid of the Concept Note, the relevance of the partnership will be evaluated only during stage 1 (Concept Note): changing the composition of the partnership would therefore impact the evaluation of its relevance.
These are the main reasons why the composition (Applicant and partners) cannot change from stage 1 to stage 2 otherwise the proposal will be rejected.

There is no number of recommended partners since this depends on the objectives of the project, its activities and results to be achieved. According to the Guidelines for Applicants, the minimum number of countries to be represented in a partnership is 4 (including at least one EU Mediterranean Country and one Mediterranean Partner Country). The Concept Note format allows up to 15 subjects involved in the partnership (Applicant + 14 partners). In case the partnership includes more than 14 partners, please use the additional partners form available upon request to the Joint Managing Authority.
In order to guarantee a smooth management of the project, it is strongly recommended to limit the number of organisations involved in the partnership to a maximum of 15 (i.e. Applicant and 14 Partners).

Provided that the Joint Managing Authority cannot give a prior opinion on the eligibility of Applicants and partners, it is recalled that according to the Financial Regulation, grants may not have the purpose or effect of producing a profit for the Beneficiary/partners (it shall cover additional activities implying additional costs not already covered by the general Budget of the European Union), must involve co-financing and may not be cumulative (i.e. the same action cannot be financed twice: through the Programme grant and e.g. the general Budget of the European Union). Moreover the Joint Research Centers (JRC) should take into account the limitation set by Art. 14 (e) of the ENPI Regulation (Regulation EC n° 1638/2006) that states that “Community institutions and bodies [are eligible], but only for the purposes of implementing support measure of the type referred to in Article 16".
Finally with regard to geographical eligibility, due to their particular international status, the JRC and the other Community institutions and bodies have no geographical constraint, so they can be based outside the eligible areas provided that their activities will be implemented for the benefit of the Programme eligible territories. However, their participation cannot contribute to the fulfillment of the minimum geographical criterion set for this call (minimum 4 countries represented whose at least one from the EU participating countries and one from the Mediterranean Partner Countries).

As per section 4.2.4 "Submission of supporting documents for provisionally selected Applications" of the Guidelines for Applicants, "where the grant requested exceeds € 500.000, an external audit report produced by an auditor, certifying the applicant's annual accounts for the last financial year available. This does not apply to public administrations, public bodies and international organisations". This means that the name of the auditor performing this check on the Applicants accounts (for the last financial year available) has to be indicated in the Full Application Form while the audit report shall be sent during only as supporting document for the verification of eligibility, upon explicit request of the JMA.

No. As stated in the Guidelines for Grant Applicants and in the glossary (Annexe J) “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. Therefore, its participation within project proposals submitted under this call is limited according to two different options: Once as Applicant or Twice as partner per each topic.

As per PRAG, the Joint Managing Authority cannot give a prior opinion on the eligibility of an organisation. The list of eligible organisations under the Programme is available section 3.1.1 of the Guidelines for Applicants according to article 14 of the Regulation (EC) No. 1638/2006 (ENPI Regulation) and to the national legislations of Mediterranean Partner Countries.
The choice of the type of organisations to be involved should be linked to the specific objective and results that a project intends to achieve. Each organisation being part of partnership shall demonstrate to have the necessary experience, skills, technical and operational capacity to contribute to achieve the set objective and results.

The Standard Contribution Agreement (specific “General and Special Conditions” for IOs) has to be used, instead of the Standard Grant Contract, when:
- the IO is the Beneficiary of the grant;
- the IO has successfully undergone a four-pillar review carried out by the European Commission. It means that the accounting, audit, control and procurement procedures standards applied by the IO offer guarantees equivalent to internationally accepted standards.
When the IO is involved as partner, it cannot use the Standard Contribution Agreement, even though the four-pillar review is satisfactory.
As far as expenditure verification and checks are concerned, the IO can nevertheless apply any verification agreement concluded between such organisation and the European Commission (article 16.2, last paragraph of the General Conditions of the Standard Grant Contract).
Moreover, the IO applies its own procurement rules if they offer guarantees equivalent to internationally accepted standards (article 8.3 of Annex IV on contract-award procedures) otherwise it will have to follow the same procurement rules foreseen for any partners.
If the IO has not undergone a four pillar assessment carried out by the Commission and for any other issues, whether it participates as Applicant or partner, it will have to apply the same rules as for the other partners (signing a declaration where it accepts them) and the Partnership Agreement concluded between the Beneficiary and the partners.

International organizations can participate in this call following the rules set in section 3.1.1 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 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 regardless their geographical location. However, they do not contribute to the fulfillment of the minimum partnership requirement (see section 3.1.2 of the Guidelines for Applicants). Therefore, international organizations cannot be taken into consideration in calculating the minimum of countries within a partnership.

The tasks and responsibilities of the Applicant are described in section 2.3 of the Guidelines for Applicants. As a general rule, the Applicant shall be directly responsible for the preparation and management of the project, not acting as an intermediary. It shall demonstrate the operational and financial capacity to manage the project. It means for instance that the Applicant submits the project proposal on behalf of the partnership, signs all financial, narrative and audit reports and is responsible for the whole partnership towards the JMA.
If the Applicant must contract specialized personnel to manage the project the following principles must be taken into account: staff, i.e. persons employed directly by the organization on the basis of labor contracts, should be listed under heading 1 “human resources” of the Budget, even if they work part time, or are recruited specifically for the project.
The recruitment must be carried out following the procedures that the organization usually follows to contract its staff (comparative procedures are highly recommended).
Persons, whose work is provided to the Beneficiary through a company in the framework of a service contract (i.e. sub-contracting), should be listed under heading 6 “subcontracted services” of the Budget. In any case all subcontractors must be contracted after the signature of the Grant Contract with the JMA through public procurement procedures as foreseen by Annex IV "Procurement by Grant Beneficiaries".

The principle is that only legal entities can participate. So 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 4 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.

The list of eligible regions is available in section 3.1.1 of the Guidelines for Applicants while the list of adjoining regions is available in section 3.1.2 of the same document. As per section 3.1.1 of the Guidelines, Applicants cannot come from adjoining regions.

As a rule, the participation to the call for strategic projects is only open to legal persons (i.e. organisations).
Physical persons are not eligible as such, therefore the participation shall be considered as that of the institution as a whole.

According to article 3.4 of the Special Conditions, sub-grants awarded by the Beneficiary are subject to the rule of origin as referred to in article 7.3.1 of the Special Conditions (modifying article 2.1 of Annex IV “Procurement by grant Beneficiaries in the context of European Community external actions”. Article 7.3.1 states as follows: “pursuant to Article 21.1 of the Regulation (EC) No 1638/2006 of the European Parliament and of the Council of 24 October 2006 laying down general provisions establishing a European Neighbourhood and Partnership Instrument, participation in the award of procurement or grant contracts financed under this Regulation shall be open to all natural persons who are nationals of, and legal persons established in, a Member State of the Community, a country that is a beneficiary of this Regulation, a country that is a beneficiary of an Instrument for Pre-Accession Assistance set up by Council Regulation (EC) No 1085/2006 of 17 July 2006 establishing an Instrument for Pre-Accession Assistance (IPA), a Member State of the EEA or international organizations”.

Associates do not have to meet the criteria set in section 3.1.1 of the Guidelines for Applicants on geographical eligibility. Therefore, associates may also be established in countries other than those eligible under the Programme.
Associates are not partners and do not have to sign the Partnership Agreement. Therefore, they cannot in any case contribute to reach the minimum partnership requirements.
They may not receive Programme funding with the exception of per diem and travel costs (these will be paid by the Beneficiary or by one or more of the partners). In case they play a role in the implementation of the project, a description of their tasks will have to be contained in the Application Form: this will be assessed during project evaluation, provided that associates will have to implement the activities at their own costs (other than those above mentioned).
It is recommended that associates sign a memorandum of understanding with the Beneficiary and partners in order to define their exact role and contribution regarding the implementation of the project and who will pay for their per diem and travel costs.

Participation in the award of procurement contracts financed under this Regulation shall be open to all natural persons who are nationals of, and legal persons established in, a Member State of the Community, a country that is a beneficiary of this Regulation, a country that is a beneficiary of an Instrument for Pre-Accession Assistance set up by Council Regulation (EC) No 1085/2006 of 17 July 2006 establishing an Instrument for Pre-Accession Assistance (IPA), a Member State of the European Economic Area (EEA) or international organisations. In particular see article 7.3.1 of the Special Conditions (modifying article 2.1 of Annex IV – Contract-award procedures – of the Standard Grant Contract) and pursuant to article 21.1 of the Regulation (EC) No 1638/2006 of the European Parliament and of the Council of 24 October 2006 laying down general provisions establishing a European Neighbourhood and Partnership Instrument.
In any case, the Applicant shall be directly responsible for the preparation and management of the project, not acting as an intermediary.

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 JMA reminds that the participation of adjoining regions 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 to a specific project and to the Programme as a whole.

Yes. According to the Joint Operational Programme (section 1.1) and to the Guidelines for Applicants (section 3.1.2), participation of partners located in adjoining regions listed in section 3.1.2 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 to a specific project and to the Programme as a whole.
Adjoining regions contribute to the fulfillment of the minimum partnership requirement, i.e. at least 4 different countries including at least one EU Mediterranean Country and one Mediterranean Partner Country.
In any case, the amount of resources allocated to partners from adjoining regions, as listed in paragraph 3.1.2 of the Guidelines for Applicants, should not exceed 20% of the budget of a project. The Applicant (Beneficiary) cannot come from an adjoining region.

Yes it can participate, if it is not represented locally in the eligible areas or if it has a local office that cannot take legal nor financial obligations, provided that it can demonstrate that the action is 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 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 JMA may require proof of the territorial competence of the institution.

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 (signing contracts) and assume financial liability, provided that this office has been established at least 2 years before the deadline set for the submission of the Concept Note. These conditions must be proved by providing supporting documents (such as statutes, registration papers and/or other official documents) that might be requested by the JMA during the evaluation process of project proposals (section 3.1.1 of the Guidelines for Applicants).

The eligibility criteria are defined in the Guidelines for Applicants (section 3.1) and, in case of particular limitations, in the text of the call for proposals. Moreover, the list of eligible actors can also be found in article 14 of EC Regulation No. 1638/2006 (ENPI Regulation). Please note that the JMA cannot give prior opinion on the eligibility of an organisation. Applicants should therefore refer to the list of eligible actors indicated in the Guidelines for Applicants and verify if the type of organisation is part of the list.

Yes, provided that the minimum partnership criterion is fulfilled (at least four countries, representing at least one EU Mediterranean Country and one Mediterranean Partner Country).

In this case, the location of the event is something the Beneficiary and partners normally cannot influence. As long as the participation in such events (seminars, trainings, 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).

As a rule, all activities financed in the framework of the project should be located inside the Programme eligible area or in the relevant adjoining regions, if the participation of partners from those regions is allowed (see section 3.1.2 of the Guidelines for Applicants). This means that an event organised for instance in Germany or Ukraine would not be eligible.

There is no formal requirement that the location of activities must be restricted to the eligible regions of the countries where the Beneficiary and partners are registered. However this must be clearly mentioned in the description of the project activities, together with the reason why the project wants to implement activities in an eligible region not represented in the partnership.

According to section 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.

3. Budget and eligible costs

As explained in the instructions for filling in the Budget, per diem covers accommodation, meals and local travels within the place of the mission and sundry expenses. The calculation of the number of per diems is based on the number of actual overnights. For example if 3 days are foreseen but only 2 overnights, only 2 per diem should be indicated.

Administrative costs and contingency reserve are not part of the list of costs that can be chosen when filling in worksheet 4: this means that only direct costs can be considered to fulfill the “50%” rule. Indirect costs and contingency reserve will be counted only if directly managed by Applicants and partners coming from Mediterranean Partner Countries (therefore counted in worksheet 3 as part of the budget allocated to MPCs).

According to article 14.2 of Annex II “General Conditions” to the Grant Contract, among the other eligible costs there are: “taxes, including VAT, where the Regulation and/or Financing Agreement with the third country under which the Contract is financed do not exclude coverage of taxes and the Beneficiary (or, where applicable, its partners) can show it cannot reclaim. Notwithstanding, the Beneficiary (or its partners) will not have to show it cannot reclaim taxes in any of the cases set out in Article 14.7”.
In particular VAT and Taxes are never eligible for Applicants and partners coming from Mediterranean Partner Countries, since the Financing Agreement signed by the EC with each MPC state that these costs are not eligible regardless the fact that an organization can reclaim them or not. Therefore Applicants or Partners from MPC should indicate, in the budget, costs not including the VAT or other taxes (the possibility to obtain invoices without VAT has to be check by each MPC organization with the competent authority in its own country).
For Applicants or partners from the EU, VAT is eligible only if the organization cannot reclaim it (see also art. 14.7 of Annex II “General Conditions” to the Grant Contract:
“The Beneficiary (or, where applicable, its partners) will not have to show it cannot reclaim taxes in any of the following cases:
– where the amount of taxes per invoice is less than EUR 200, within a maximum
of EUR 2 500, representing not more than 5% of the Contracting Authority's
contribution;
– where the Beneficiary can demonstrate that the steps necessary for recovery of
taxes oblige it to incur costs in a country where it only performs the relevant
operations on an ad hoc and isolated basis; and that these costs for recovery (e.g.,
registration fees in the country or the costs for appointing a tax representative,
declaration fees, etc.) clearly exceed the amount of the taxes declared to the
Contracting Authority;
– where a country has been declared in crisis situation or in the need for emergency
and post-emergency assistance by the European Commission. This exception is
limited to the period in which the declaration is in force. The Beneficiary shall
be informed in writing thereof;
– Where the Action relates to the protection of fundamental rights of peoples, as provided for in the Special Conditions.
The Beneficiary shall certify that the concerned taxes have not been or will not be recovered from the local tax authorities and prove that the above requirements are met at the latest when submitting the final report”.

Yes it is possible to launch a single tender to purchase equipment or supplies and then have separate invoices for each organisation that will pay its own quota. However please note that:
- each organization must agree to have a common procedure on a clear legal basis (e.g. Partnership Agreement)
- the organisation has to make sure that it has the possibility to pay an invoice issued by the provider contracted by a different organisation (Applicant or partner that launched the tender according to the applicable procurement rules).
- the use of the common tender has to be mentioned in the Full Application Form in the description of the equipment or supplies to be purchased to implement project activities.
The costs will have to be indicated in worksheet 1 of the Budget according to the quota that each organization will manage.
Please note that art. 7.3 of Annex II “General Conditions” as amended by art. 7.2.9 of the Grant Contract Special Conditions:
“Beneficiaries and partners located in EU Member States may implement activities in Mediterranean Partner Countries involving equipment, vehicles and supplies. Unless otherwise specified in the Special Conditions, the equipment, vehicles and supplies paid for by the Budget for the Action must be transferred to partners in the countries where the activities were carried out or to the final recipients of the Action, at the latest when submitting the final report. Copies of the proofs of transfers of equipments and vehicles, the purchase cost of which was more than EUR 5.000 per item, must be attached to the final report. Such proofs must be kept for control purposes in all other cases”

Staff or expert costs can be included only in case an organisation hires dedicated personnel to work in a MPC. In the contract between the EU organisation (Applicant/partner) with the expert, the place where the hired person will carry out the project activities should be clearly indicated in the contract.
Please note that temporary missions of staff/experts to attend project meetings or seminars shall not be considered as eligible costs for activities to be implemented in MPC (this in line with the non eligibility of the travel costs).

Given the limited amount of national funds, the JMA will be able to confirm the resources available and percentage of national co-financing only during the negotiation phase of the Grant Contracts.
Therefore Italian Applicants and partners should choose in worksheet 3 of the Budget (“Sources of funding”), the source “Contribution from other EU Institutions or Member States” indicating in the row “name and conditions” that the amount will be confirmed upon availability of funds. Please note that in case of non availability of the maximum national co-financing rate (10% of the total eligible costs managed by Italian Applicants/partners), the remaining co-financing will have to be covered using the other possible sources of funding (staff costs and own resources).

According to article 14.4 of Annex II “General Conditions” to the Standard Grant Contract, administrative costs are calculated at project level. However these are linked to the direct eligible costs incurred by all the partners.
Therefore these costs will have to be distributed according to the percentage (not exceeding 7%) indicated in worksheet 1 - row 11 - of the Budget among the Applicant and its partners based on the direct costs managed by each organisation (the detail per partner will have to be indicated in worksheet 3 of the Budget).
Please note that according to the same article,“The flat-rate funding in respect of indirect costs does not need to be supported by accounting documents. Indirect costs are eligible provided that they do not include costs assigned to another heading of the budget of this Contract.”

Yes, it is possible as indicated in article 9.2 of the General Conditions (Annex II to the Grant Contract), modified by article 7.4.3 of the Special Conditions. Any budget transfer between main budget headings or partners involves a variation of more than 15% of the amount originally entered has to be must be set out in writing in an addendum that must be approved by the Joint Monitoring Committee.
If the “amendment to the Budget or to the Description of the Action does not affect the basic purpose of the Action and the financial impact is limited to a transfer between main budget headings involving a variation of 15% or less of the amount originally entered (or as modified by addendum), or a transfer between partners budget involving a variation of 15% or less of the amount originally entered (or as modified by addendum), the Beneficiary may amend the Budget and inform the Contracting Authority accordingly in writing within 30 calendar days. This method may not be used to amend the headings for administrative costs or the contingency reserve ”.

Subcontracting is the possibility to externalise some services through a public procurement procedure based on the provisions set by Annex IV of the Grant Contract (for example to externalise the design of the website to a company or the external audit service for verification of expenditures). These costs must be indicated under budget line n. 6 of Annex III (Budget for the Project)in worksheet 1.
Sub-granting refers to the possibility to re-grant a portion of the project budget through a public procedure indicating the selection criteria that will be used to award the sub-grant. The maximum amount that can be awarded is 100.000 euro, taking into consideration that no sub-grantee can receive more than 10.000 euro. An example of sub-granting can be the need to implement pilot initiatives with local actors (e.g. students, farmers, SMEs, etc.).
Both the Applicant or partners may award the sub-grant provided that the overall amount cannot exceed 100.000 euro and according to the selection criteria described in the Full Application Form.

According to article 7.3.1 of the Grant Contract (Special Conditions) modifying art. 2.1 of Annex II “General Conditions”, the rule of nationality implies that experts to be directly contracted by the Applicant or partners must fulfil the provisions set by this article (reported below).
7.3.1 Article 2.1 shall be replaced as follows:
“[...] Pursuant to Article 21.1 of the Regulation (EC) No 1638/2006 of the European Parliament and of the Council of 24 October 2006 laying down general provisions establishing a European Neighbourhood and Partnership Instrument, participation in the award of procurement or grant contracts financed under this Regulation shall be open to all natural persons who are nationals of, and legal persons established in, a Member State of the Community, a country that is a beneficiary of this Regulation, a country that is a beneficiary of an Instrument for Pre-Accession Assistance set up by Council Regulation (EC) No 1085/2006 of 17 July 2006 establishing an Instrument for Pre-Accession Assistance (IPA), a Member State of the EEA or international organisations.
Tenderers must state, in the tender, the country of which they are nationals by presenting the usual proof of nationality under their national legislation.......”

The only exception is foreseen in the same article 7.3.1: “This rule does not apply to the experts proposed by service providers taking part in tender procedures or service contracts financed by the grant”.

This means that if the project foresees to subcontract a portion of the activities to service provider (for example to implement the monitoring system), the company must respect the rule of nationality foreseen by article 7.3.2 of the Grant Contract replacing article 2.2 of Annex II “General Conditions” (see question and answer n. 2.12) and therefore it has to be established in the areas mentioned in this article. However the company can have, in its team of expert, persons coming from countries not mentioned in the article (for example a German company that has in the team of expert an American engineer).

In the framework of EC financed grant contracts for external actions, the actual cost of the purchase or rental of equipment is fully eligible for financing, irrespective of the duration of the project and the period of depreciation.

According to article 15.7 of the General Conditions (Annex II to the Grant Contract), a financial guarantee will be requested to Beneficiaries “if the total sum of pre-financing paid under the Contract is more than 80% of the Contract amount and exceeds EUR 60 000, its payment must be fully covered by a financial guarantee. Where the Beneficiary is a non-governmental organisation, such guarantee is requested if the total sum of pre-financing paid under the Contract is more than EUR 1 million or 90% of the Contract amount. The financial guarantee must be denominated in euro or local currency, conforming to the model in Annex VIII and, unless the Contracting Authority otherwise agrees, provided by an approved bank or financial institution established in one of the Member States of the European Community. This guarantee shall remain in force until its release by the Contracting Authority when the total amount of pre-financing under the Contract is once again less than EUR 1 million or after payment of the balance.
This provision shall not apply if the Beneficiary is a government department or public body or an international organisation, unless otherwise stipulated in the Special Conditions”.

Even though International Organisations (IO) do not contribute to the requirement concerning the minimum geographical composition of the partnership (see Guidelines for Applicants, section 3.1.1), if an IO is located in a MPC, it contributes to the fulfillment of the so called "50%” rule (see "Guidelines for Applicants, section 3.2.1). The portion of the budget managed by an International Organisation based in a MPC will count to satisfy this requirement.

Provided that the administrative costs cannot exceed 7% of the total direct eligible costs at project level, the JMA suggests to allocate the same percentage to all partners.

No, there is no pre-defined threshold, except for administrative costs (not exceeding 7% of the direct eligible costs) and contingency reserve (not exceeding 5% of the direct eligible costs). It is recommended to consult the different criteria in the Project Evaluation Grid (section 4.2.2 of the Guidelines for Applicants) that will be used to assess the Budget.

According to par. 4.1.1 of the Guidelines for Applicants, the total eligible budget costs cannot vary from the initial estimate by more than 20% provided that the limits set under paragraphs 2.5 (% of Programme contribution and co-financing) and 3.3 (total eligible budget costs) are respected. This means that the ceilings set by the call must be respected: a minimum of 2.000.000 euro up to a maximum of 5.000.000 euro of total eligible costs including both the ENPI contribution (maximum 90% of project total eligible costs) and the project co-financing (minimum 10%). See also questions n. 3.1 and 3.7 published on the Programme website under the “Questions and answers” section of the call for strategic projects.

Provided that the JMA cannot give a prior opinion on the eligibility of costs, the general principle mentioned in section  2.5 of the Guidelines for Grant Applicants is that at least 50% of the total eligible budget costs of the project shall be dedicated to activities implemented in the Mediterranean Partner Countries territories as listed in section 3.1.1. In order to fulfill this requirement, project proposals shall:
- foresee to allocate at least the 50% of the budget costs to the partners from the Mediterranean Partner Countries
or
- in case the financial allocation to partners from Mediterranean Partner Countries is lower than the said minimum percentage, the difference up to the 50% shall be justified by activities implemented by EU Applicant or partner/s and/or International Organisations in the Mediterranean Partner Countries. The said budget costs shall be indicated and justified in the dedicated budget table in the Grant Application Form.
 
As far as the travel cost category is concerned, the principle implies that these costs are counted in the budget of each partner.
Therefore if they are incurred by the EU partners to attend events in Mediterranean Partner Countries they cannot be counted in order to fulfill the above mentioned criterion. Please note that detailed instructions will be provided on this point to projects pre-selected to stage 2, i.e. invited to submit a Full Application Form.

The per diem corresponding to the country of destination shall be applied. The per diem scales published by the European Commission are available here. (http://ec.europa.eu/europeaid/work/procedures/implementation/per_diems/i...)

According to article 14.2 of the General Conditions (Annex II of the Grant Contract), travel and subsistence costs are eligible provided that “they do not exceed those normally borne by the Beneficiary or its partners, as the case may be”. Therefore travel and subsistence costs must follow the rules usually applied by the organisation. In case the organisation uses flat-rate reimbursement (per diem), these must not exceed the rates set out published by the European Commission at the time of the signing of the Grant Contract. The per diem scales of the European Commission are available here. (http://ec.europa.eu/europeaid/work/procedures/implementation/per_diems/i...)
No maximum amount has been set for a project, but the total cost of travels cannot constitute the bulk of the project budget, since travels should aim at contributing to achieve the expected project results.

The purchase or rent of equipment/technology must follow the procurement rules set in Annex IV of the Grant Contract (see question 3.20). Moreover according to PRAG (paragraph 6.1.1) “under no circumstances may the grant give rise to profits”: therefore it is not possible to purchase or rent the equipment form a partner participating in the project.

As per PRAG, the JMA cannot give a prior opinion on the eligibility of an Applicant, a partner, a project or specific activities. According to section 3.2.2 of the Guidelines for Applicants, the projects concerning only or mainly the following activities are ineligible:
- individual sponsorships for participation in workshops, seminars, conferences, congresses
- individual scholarships for studies or training courses;
- pure academic and research oriented activities;
- studies;
- one-off conferences: conferences can only be funded if they form part of a wider range of activities to be implemented in the life-time of the project. For these purposes, preparatory activities for a conference and the publication of the proceedings of the conference do not, in themselves, constitute such "wider activities”.

Yes. According to section 3.3.2, credits to third parties are ineligible costs. Therefore micro-credits activities are not considered as eligible costs under this call (see also article 14.6 of Annex II “General Conditions” attached to the Grant Contract - Annex D).

If the implementation of the project requires procurement by the Beneficiary or the partners to purchase equipment, services or works, the rules set by Annex IV “Procurement by grant Beneficiaries in the context of European Union external actions” must be applied. As general principles, the contract must be awarded to the most economically advantageous tender (i.e., the tender offering the best price-quality ratio), in accordance with the principles of transparency and fair competition for potential contractors and taking care to avoid any conflicts of interest. In the event of failure to comply with the rules set out in annex IV, expenditure on the operations in question is not eligible for Community financing.

According to Commission Regulation (EC) No 1998/2006 (http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2006:379:0005...)on de minimis regime, aid of no more than € 200.000 granted over a period of three years is not regarded as State aid. A specific ceiling of € 100.000 applies to road transport. The Regulation does not apply to aid for fisheries and aquaculture, the primary production of agricultural products (for this specific field please refer to (EC) No 875/2007 at http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2007:193:0006...), export-related activities, the coal sector, the acquisition of road freight transport vehicles or firms in difficulty, or to aid tied to the use of domestic over imported goods. It applies to aid granted to firms in all other sectors, including transport and, on certain conditions, for the processing and marketing of agricultural products.
The JMA cannot give a prior opinion on the respect of this regime since this will be assessed during the evaluation of project proposals and because it also depends on the nature of the activities to be implemented. Interested Applicants and partners are thus strongly invited to consult Commission Regulation (EC) No 1998/2006.
Moreover the possibility to apply the provisions of the Commission Communication on "Temporary Community framework for State aid measures to support access to finance in the current financial and economic crisis" will depend on each EU Member State. Therefore it is highly recommended to contact the authority/office in charge of State aid issues at national level in order to find out whether this is applicable or not. Please note that the said temporary framework does not apply to subjects belonging to Cyprus and Italy receiving funding under the ENPI CBC Mediterranean Sea Basin Programme.
For more detailed information, see the Note on State Aid(http://www.enpicbcmed.eu/documenti/29_38_20091009161313.pdf).

As a general rule, the JMA cannot give a prior opinion on the eligibility of a budget item. Eligible costs are listed in article 14.2 of Annex II “General Conditions”.
Some issues should be taken into consideration for the development of a prototype. As per section 6.2.10 of the Practical Guide to Contract Procedures for the EU external Actions (PRAG) "Grants may not have the purpose or effect of producing a profit for the beneficiary...".
Moreover, according to art. 7.2 of the General Conditions, as modified by art. 7.2.8 of the Special Conditions "[...] the Beneficiary grants the Contracting Authority the right to use freely (free of charge) and as both see fit all documents deriving from the Action other than those reports referred to in Article 2, whatever their form, provided it does not thereby breach existing industrial and intellectual property rights".

According to art. 14 of Annex II to the Grant Contract “General Conditions” (as modified by article 7.2.12 of the Special Conditions) , the Programme can finance "small" infrastructures (defined as "basic facilities, services, and installations needed for the functioning of a community or society"). The "small" size also relates to the concerned costs compared with the overall project budget.
A clear identification of what has to be considered as "Infrastructure" compared with the items that shall be included under the "Equipment" cost category is a pre-condition. In order to be eligible, according to section 3.3.1 of the Guidelines, the cost of infrastructures must be listed and specified in the Budget for appraisal by the Project Selection Committee due to their potential territorial impact.
Furthermore, there is no pre-defined maximum percentage set for any cost category of the Budget (with the exception of “Administrative costs” and “Contingency reserve”), and the rules set by Annex IV to the Grant Contract “Procurement by grant Beneficiaries” shall apply to purchase the foreseen infrastructures.

The payments to projects follow the rules set by Article 15 “Payment and interest on late payment” of Annex II “General Conditions”.
Option 2 mentioned by the said article shall apply as far as the payments are concerned. In particular, all payments to projects will follow the calendar established by the JMA and the Beneficiary in the Special Conditions. For the first pre-financing the JMA can advance up to 80% of the Programme contribution foreseen for the first year. In any case the total sum of pre-financing under the Contract may not exceed 90% of the amount referred to in Article 3.2 of the Special Conditions (i.e the Programme contribution).
According to article 4.3 of the Special Conditions, the first pre-financing is transferred to the Beneficiary by the JMA within 45 days from the signature of the Grant Contract, provided that the Beneficiary has communicated to the JMA the name of external auditor that will perform the expenditure verification (see also article 5.2 of the Special Conditions).
Finally, according to the Joint Operational Programme, the Beneficiary is provided with 30 calendar days to transfer the respective financing to its partners. Further payments will be made according to options 1 or 2 defined in the Special Conditions (article 4) and will be based on the level of certified expenditures of the Beneficiary and each partner and the forecast expenditures foreseen for the following year (see also article 15 of the General Conditions).

Yes, as stated in par. 3.3.1 of the Guidelines for Applicants and according to art. 14.2 of the General Conditions (Annex II), the cost of staff assigned to the project, corresponding to actual gross salaries including social security charges and other remuneration-related costs, is eligible. The salaries and costs must not exceed those normally borne by the Beneficiary or its partners, unless it is justified by showing that it is essential to carry out the activities of the project.

There are no billing threshold for Applicants. However the financial capacity to manage the budget of the project will be assessed during stage 2 (see evaluation criteria n. 1.3 and 1.4 of the Full Application Form in the Guidelines for Applicants).

According to par. 2.5 of the Guidelines for Applicants, a same organisation cannot manage more than 30% of the total eligible costs. Moreover at least 50% of the total eligible budget costs of the project shall be dedicated to activities implemented in the Mediterranean Partner Countries territories as listed in section 3.1.1. of the Guidelines for Applicants.

There is no minimum threshold of co-financing set for each partner. The co-financing shall be provided at project level and shall amount to a minimum of 10% of the total eligible costs as indicated in the Budget for the Project (Annex III - worksheet 3).
The co-financing can come from the Applicant/partner’s own resources or from funds of other national/local institutions, etc. "In kind" co-financing is not eligible: the Beneficiary and its partners will therefore have to provide evidence of actual payments for all project expenditures, irrespective of the source of funding. The expenditure for staff (Human Resources) is not considered as contribution “in kind” and can be considered as co-financing (see art. 14.5 of Annex II “General Conditions”).

No maximum threshold applies however these costs have to be duly justified in worksheet 2 of Annex III “Budget for the Project”. In spite of that, it should be underlined that as per article 1.3 of the General Conditions “the Beneficiary may subcontract a limited portion of the Action. The bulk of the Action must, however, be undertaken by the Beneficiary and……his partners”.

The CIPE Decree n. 36 of 15.06.2007 indicates that Italian Applicants/partners of ENPI CBCB MED projects can recover their eligible costs once certified by accessing the "Fondo di Rotazione" national mechanism managed by Ministry of Economy and Finance (IGRUE), up to a maximum of 10% of their own budget. However, due to the current limitations of available funds, the JMA is verifying with the above mentioned authority if a reduction on the maximum amount or percentage shall apply. An official note will be published soon on the Programme website.

As indicated in article 2 of Annex IV (Contract-award procedures), the participation in tender procedures administered by the Beneficiary shall comply with the nationality rule. However article 2.3 of the same document, as replaced by article 7.3.3 of the Special Conditions, sets some derogations to the nationality rule. In particular “derogations as provided for in paragraph 2 may be justified on the basis of the unavailability of products and services in the markets of the countries concerned, for reasons of extreme urgency, or if the eligibility rules would make the realisation of a project, a programme or an action impossible or exceedingly difficult."

Yes, audit costs are eligible (article 14 of the General Conditions), within a maximum of 3% of the project budget (section 3.3.1 of the Joint Operational Programme).

There is no minimum threshold set for the co-financing by each partner. The co-financing shall be provided at project level and shall amount to a minimum of 10% of the total eligible costs as indicated in the Budget for the Project (Annex III, worksheet 3).

Yes, the cost of staff assigned to the Project is not a contribution in kind and may be considered as co-financing in the Budget for the Project when paid by the Beneficiary or his partners (article 7.2.13 of the Special Conditions modifying art. 14.5 of the General Conditions).

No, any contributions in kind (such as voluntary work or provision of offices) which must be described in the Application Form, do not represent actual expenditures and are not eligible costs (article 14.5 of the General Conditions). Therefore, contributions in kind may not be treated as co-financing by the Beneficiary. If the proposal foresees contributions in kind despite their ineligibility, such contributions have to be provided.

There is no fixed prior apportionment that shall be given to the Beneficiary or to partners. However, according to paragraph 2.5 of the Guidelines for Applicants “Each participating organisation cannot manage more than 30 % of the total eligible budget (the only exception is when there is only one partner from Mediterranean Partner Countries which might have 50% of the total budget). The project budget shall be drafted in order to guarantee the coherence between the activities to be implemented by each subject and their costs.

No, they are not eligible. According to section 3.3 of the Guidelines for Applicants and article 14 of the General Conditions, grants may only cover costs incurred after the date on which the Grant Contract is signed or a later date indicated in the Contract.

The JMA cannot give a prior opinion on the eligibility of the costs of some specific activities/items. All information regarding eligible costs can be found in section 3.3 of the Guidelines for Applicants and in article 14 of the General Conditions (Annex II of the Standard Grant Contract).

Total budget of a strategic project ranges from a minimum of 2.000.000 euro up to a maximum of 5.000.000 euro. These amounts shall include both the ENPI contribution (90% of project total eligible costs) and the project co-financing (10%).

4. How to fill in the Concept Note / Full application Form

As per the "Instructions to fill in the Concept Note" (included in Annex A), the national registration number refers to any kind of official alphanumeric code assigned to identify organisations according to the respective national system of registration. An indicative list of most common identification numbers could include fiscal registration numbers (e.g. VAT), insurance or social security codes, etc. The reference to the “national registration number” remains open to all possible legal identification code adopted by each participating country. It is compulsory to fill in this field otherwise the Concept Note cannot be validated. Furthermore, this information is relevant in order to check the compliance with the eligibility of the organisation / project (section 3.2.1 of the Guidelines) with regard to the limitation set for the participation under this call.

As per section 3.1.2 of the Guidelines for Applicants, “the associates have to be mentioned in the Full Application Form - Associates of the partnership participating in the Project”. Therefore, there is no obligation to list the associates in the Concept Note all the more that there is no dedicated section for associates in the Concept Note.
In case the associates play an active role in the implementation of some project activities and contribute to the achievement of some expected results, a brief description of their tasks may be included in the Concept Note (for instance in sections 2.3 “Relevance of the partnership” or 3.2 “Feasibility of the project”) provided that the number of characters is limited.

As per section 4.1.2 of the Guidelines, the Concept Note together with the Declaration by the Applicant (for the Concept Note) must be submitted in one (1) paper original and one (1) copy in A4 size, each bound. The Declaration by the Applicant must be stapled separately and enclosed in the envelope. Concept Notes must be submitted also in electronic format (CD-ROM or USB). The electronic format must contain exactly the same information as the paper version enclosed (the code at the bottom of each page is the same).

No. As stated in the last page of the “Practical Instruction on How to fill the Concept Note”, you only need to validate the Concept Note.
So you shall “CHECK” your Concept Note first and once all fields are duly completed you shall “VALIDATE” it and save this version in your PC for printing.
Please note that once the Concept Note has been validated, it cannot be changed anymore. It is therefore strongly recommended to save intermediary versions of the Concept Note before its validation.
Please note that the validated version will be marked by a unique code appearing at the bottom of each page. You shall print this version and send it along with the electronic file (saved on a CD-ROM or USB Key) and the Declaration by the Applicant (original handwritten signed version).
It is of utmost importance to check that both versions of the Concept Note (paper and electronic) have the same code at the bottom of each page to ensure that the two versions are identical.

The format of the Concept Note cannot be changed. In order to facilitate the drafting of the Concept Note, it is recommended to read the practical instructions available in Annex A.