British net of nongovernmental organizations BOND has sent most frequent asked questions and answers regarding grants from European commisions for development education
EC funding Q&A’s from BOND members, collated on 4th Feb 2008
Re-granting
Q1) Does a sub-grant have to go to a partner? Could it go to a Local Authority who is not a partner?
A. As foreseen under point 2.1.2 of the Guidelines for grant applicants, partner organisations (which obviously must fulfil the eligibility criteria) participate in implementing an action and the costs they incur are eligible in the same way as those incurred by the grant beneficiary. This would therefore not be considered as sub-granting. As long as the sub-grant is granted within the conditions set out under point 2.1.3 of the Guidelines, a Local Authority could in principle be the beneficiary of such a sub-grant.
Q2) Can the organisation who receives the sub-grant open a separate bank account for part of the funds received which will go towards specific activities?
A. We are not sure to unerstand your question correctly. An organisation can surely open a separate bank account, but it is not clear why that would then only be for 'part of the funds received'.
Q3) What sort of financial accounting is required for sub-grants?
A. For sub-grants, detailed accounting is required as for any other project expenditure. However, the original receipts/invoices etc. will normally remain with the 'beneficiary of the sub-grant' whereas the body having granted the sub-grant (the organisation in charge of the management of the project in the field) will receive as justifying documents lists of expenditure, copies of invoices etc. For the list of justifying documents, in particular, please refer to article 16.3 of the "General Conditions applicable to European Community-financed grant contracts for external actions" (http://ec.europa.eu/europeaid/work/procedures/documents/execution/grants/e3h_2gencond_en.pdf).
Q4) Can the organisation who receives the sub-grant pass on some of the funds to other organisations or groups to implement part of the activity, eg. To a local community group for rehabilitation of a water pond?
A. Sub-grants are in principle granted to 'third parties'. Whether this is done directly by the applicant or by a partner organisation (see point 1 above) will depend on how and by whom the project is administered in the field. Such third parties will normally be local groupings like Village Development Committees, Farmers Associations etc.
Q5) I would like some clarification regarding what the EC understands by "third parties". For example, would the EC consider re-granting giving money to local committees of direct beneficiaries or to grassroots organisations (not the official project partners) for some of the work included in the proposal and budget? I would welcome a clear definition and some examples, as at the moment neither the Guidelines nor the Financial Regulation explain this in detail.
A. Please note that partners and associates are not considered as third parties. Third parties would for instance be groupings of beneficiaries such as village development committees, village clubs, women's associations etc.
Micro-credit and revolving funds
Q1) This new requirement introduced by the EC seems to apply to financial micro-credit/revolving funds. However, it does not seem very adequate for small in-kind revolving funds such as revolving funds of seeds and animals as some of our projects have. Could you please clarify if the guidelines refer to both financial and non-financial revolving funds?
A. Please note that "in-kind" revolving funds are indeed not foreseen by the provisions of annex H (additional criteria and conditions for proposals involving microfinance actions).
PADOR
Q1) Is registration in PADOR is compulsory for the NSA CPFs out now (it is not but if you want to use it you have to do so before submission of CN).
A. As stipulated in section 2.2 of the Guidelines for grant applicants for the Non-State Actors and Local Authorities in Development, Actions in partner countries (in-country) Call for Proposals, prior registration of the applicant in the PADOR system is not obligatory.
Nevertheless, should an applicant choose to register, the registration should take place before submitting a Concept Note.
Defining Local Authorities (LAs)
Q1) With reference to the above call for proposals, can you please define the nature of Local Authorities? Do they include any non-national state body including local offices of national Ministries eg District Ministry of Health, Provincial Ministry of Education?
A. Please note that Local Authorities are considered to be the governmental structures below the central government level, including regional and local bodies.
NSAs partnering with LAs
Q1) Whether European NSAs can partner with LAs in developing countries (they can)
A. No restrictions shall apply to partnerships with NSA or LA from the countries listed in section 1.3 of the Guidelines as long as the eligibility criteria for applicants and partners will be satisfied. Please refer in this respect to section 2.1.1 of the Guidelines paying attention as well to footnote n° 8 which stipulates that for the following targeted partner countries, applications may only be submitted by NSAs: Azerbaijan, China, Iran, Mongolia, North Korea and Swaziland. Applications proposing LAs (as partners) from these countries are not eligible under the present call and may therefore not be taken into consideration.
Q2) Can a Ministry of Social Welfare (i.e. national government ministry) be a Partner? Or do the Applicant have to form a partnership with Local Authorities such as Provencial Departments that come under the Ministry, instead of the Ministry at the national level?
A. Regarding Local Authorities acting as applicants or partners, please note that these shall be governmental structures below central government level, including regional and local bodies.
Q3) Can some of the actions take place in the country of the European Applicant/Partner?
A. For the location of eligible actions, please refer to section 2.1.3 of the present 'Guidelines for grant applicants', which stipulates, inter alia, that "If duly justified, certain project activities, notably in view of trans-national exchanges and for networking/coordination purposes, may take place in other countries".
Q4) Can a Non-State Actor in an EU Member State which has no physical office in one of the countries where the Action takes place be the Main Applicant, if the Applicant has worked with the local Partners before?
And,
Can a European NSA with physical office presence in two of the four countries where the proposed Action takes place be the main appilcant if another European NSA has offices in all of the four coutnries?
A. For the list of eligibility criteria applicable for this call for proposals, please consult section 2.1.1 of the 'Guidelines for grant applicants'. A 'physical office in a targeted country' is not amongst the eligibility requirements for the European NSAs.
