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Publication - Advice and Guidance

European Structural and Investment Funds: document retention guidance

Guidance on document retention for beneficiaries of European Structural and Investment Funds (ESIFs) between 2014 and 2020.

An important aspect of the 2014 – 2020 European Structural Fund Programmes is the responsibility of beneficiaries (as defined in Article 2 (10) of EU Regulation 1303/2013) to ensure the retention of all appropriate project records and documentation within both the Strategic Intervention and associated Operations. This is necessary in order to fully evidence outcomes and/or demonstrate a clear and transparent audit and procurement trail.

Beneficiaries must ensure that robust systems and controls are in place to maintain and monitor access to documentation throughout the retention period. All documents (including any electronic information) must be readily accessible to requests from Managing Authority, European Commission etc.

Document retention periods

Document retention periods are no longer linked to final closure of the Programmes.

The retention date will either be:

  • on Operations for which the total approved eligible expenditure is less than €1,000,000, for a period of three years from 31 December following the submission of the accounts in which the expenditure of the operation is included.
  • in the case of Operations other than those referred to in the first subparagraph, all supporting documents shall be made available for a two year period from 31 December following the submission of the accounts in which the final expenditure of the completed operation is included.

The Managing Authority may decide to apply to Operations for which the total eligible expenditure is less than €1,000,000 the rule referred to in the second subparagraph.

The Managing Authority must and shall inform beneficiaries in writing of the start date for determining the document retention period and the retention period.

The beneficiary may still need to retain documents for a longer period if required by the applicable State Aid rules or if audits or investigations are underway and the beneficiary is specifically advised to retain the audit trails until further notice.

Level of documentation

The level of documentation required may differ depending on the cost models employed. The following list details the documentation that must be retained:

Unit Costs

Historical data used to justify/evidence the standard costs levels agreed.

All documents required to fully evidence outcomes e.g. participant records, SME records etc.

Flat Rate and Direct Costs

All documentation to justify the flat-rate model used. A full and transparent audit trail relating to the direct costs e.g. payslips, invoices, BACs lists, bank statements.

Procurement

Documents that fully demonstrate that open or selective tendering has taken place in line with the rules relating to public procurement i.e. call for tenders, selection criteria, scoring sheets, correspondence offering and accepting the contract, adverts and award notices in the OJEU etc.

A full and transparent audit trail e.g. invoices, BACs lists, bank statements.

Grant Schemes and Challenge Funds

All documentation that supports grant scheme/challenge fund process i.e. guidance documents, application forms, approval documents, offer letters and claim forms.

A full and transparent audit trail e.g. invoices, BACs lists, bank statements.

Format of documents

European Commission regulations allow for documents to be retained as either the original paper copies or as an electronic copy of the originals. The regulations allow for the electronic storage of documents provided that they are stored on a recognised data carrier (e.g. CD ROM, Hard Disk or Magnetic Disk), are certified as being copies of the original, meet national standards and are auditable.

For each data carrier used, beneficiaries must retain a signed declaration that the documents held within the data carrier are certified as being true copies of the originals.

Minimum requirements associated with completion of the declaration are:

  • all declarations must be made available on request;
  • documents can be certified as true copies of the original document either individually or as a group of documents; however a declaration will be required each time documents(s) are copied and retained for audit purposes;
  • the declaration can be kept as an electronic or paper copy.
  • the declaration can be included on the electronic copy of the documents and stored electronically. If the document(s) are certified using a paper copy it is extremely important that it is stored with the appropriate stored data carrier

For the purposes of our verifications and audits, you should keep a document that describes the procedures you have undertaken to obtain the necessary assurance that adequate IT security standards are in place to rely on the information held electronically / digitally.

If you are unable to obtain the necessary assurances on the IT security standards, then the records will not be acceptable for EC/SGESFD compliance purposes. [article 140(6) of EU 1303/2013].

Conditions for accepting digitised, scanned, replica digital versions of original paper documents

Beneficiaries using scanning, e-archiving or image processing systems (where original paper documents are scanned and stored in digital form) must ensure that certification processes and controls are in place that, at least:

  • guarantee that each 'e-document' (scanned image) is identical to the paper original.
  • make it impossible to scan the same paper document to produce several different e-documents of the same original document (each e-document remains unique and cannot be re-used for any other than its initial purpose).
  • where the document evidences a financial transaction, the approval, accounting and payment process for each e-document should be unique (it should not be possible to approve, account for, or pay the same e-document twice).
  • once scanned, it must be impossible to amend e-documents or to create altered copies (or amended/altered versions are held as separate versions and the original, unaltered version of the image remains available for audit purposes).

Verifications and audits may ask to examine the policies and procedures in place to provide assurance of the above certification processes and controls, and may also ask to observe the scanning and certification process taking place in real time.

Certified true copies of original paper documents (photocopies)

The photocopied document must contain a 'certification statement'. The certification declaration must be annotated on, or appended to, the copy. The original document does not need to be marked.

If a document contains multiple pages then the first page should be certified and the number of attached pages indicated on the front page (alternatively, each page could be certified).

The certification statement must be signed and dated by an employee who can vouch that the copy is a true replica image of the original.

See Article 140 of EU Regulation 1303/2013.

Published:
25 Nov 2015
European Structural and Investment Funds: document retention guidance