FAQs related to funding synergies FAQs related to funding synergies

Question 1.1: Is it possible to finance in-kind contributions to research infrastructures in other Member States (e.g. contribution to ESFRI) with ESIF? In case it is possible, the Member state sees auditing as a cumbersome and risky exercise.

The derogation established in Article 70(2) CPR(1) allows the implementation of operations outside the programme area (for instance in adjacent regions or in other Member States), but within the Union. Under this derogation, operations can thus be implemented in another territory of the same Member State or even in another Member State, but not outside the Union, provided that the conditions of the article are satisfied. The object/machinery/laboratory equipment located outside the programme area can be supported as long as it respects the following:

  • The conditions of Article 70(2) CPR which includes demonstrating that the operation is for the benefit of the programme area, and that overall such investments must not exceed 15% of the ERDF and Cohesion Fund support at the level of priority.
  • The provisions of Article 69(1) CPR on contributions in kind and in particular paragraph b on the market value of the in kind contribution and paragraph c on the independent assessment and verification of the value.

In addition, we would draw your attention to Commissioner Hahn's letter of 25/09/2013 on the eligibility of membership fees to RDI institutions like CERN (Ref. Ares(2013)3112468), which explains that they are not eligible for ERDF support. Therefore in kind contributions in lieu of a membership fee would also be considered as not eligible.

(1) This provision does not apply to the ESF (see Article 70(4) CPR). For ESF operations implemented outside the programme area, but within the Union, see Article 13(2) ESF Regulation.

The final decision is left to the relevant policy-making bodies at the appropriate territorial level, taking into consideration the institutional structure of the country concerned and the actual responsibilities for the policy processes in terms of both research/innovation strategies and public funding tools. We strongly suggest to register at the most relevant territorial level (NUTS I, II or III) with respect to the mentioned policy processes. The leading department should thus be the one having the responsibilities for the preparation/implementation of innovation strategies and/or the management of funding tools (like the EU Structural Funds). We also recommend that all the main departments involved, as well as major stakeholders, are included in the registration. With regard to the mentioned policy processes, there might be the case, for specific countries, that registration is recommended at both national and regional levels

Articles 67(1), 69(1) and 70(2) CPR

Question 1.2: Are there recommendations on how to manage the situation that the result of financial support (the in-kind contribution) will be placed outside the programme area? Even if the rules of the relevant OP were to be adapted to that situation, will also the audit institutions (both at national and European level) be aware of that possibility?

The principle of avoidance of double funding applies fully here.

Question 2: What will be the method of financing foreign partners in consortium, that do not fall within the programme area but for whom article 70 might be applied? An example of pro-rata calculation in such a situation would be welcome.

It is up to the Managing Authority (MA) to elaborate with other MA on how to deal with this. More specifically, article 70 (1) CPR establishes the general rule that operations financed by the ESI Funds (except ETC) have to be located in the programme area(1). In other words, as a general rule, operations have to be located in the geographical area or category of region (in the case of ERDF and ESF) from which the funding is drawn. Therefore, if the operation is fully implemented in the programme area then it can be funded fully from the programme.

A derogation is established in Article 70(2) CPR under which it is allowed that the implementation of operations may be outside the programme area (for instance in adjacent regions or in other Member States), but within the Union, provided that the conditions of this article are satisfied.

Thus, if different parts of the consortium are responsible for implementing operations outside the programme area, then it is possible for the programme to fund those parts of the operation as long as they respect the provisions of Article 70 (2) CPR.

For the ERDF (except ETC), Cohesion Fund and EMFF, the amount allocated under the programme to operations located outside the programme area cannot exceed 15 % of the support at the level of the priority, or 5 % of the support from the EAFRD at the level of the programme. For the ERDF (except ETC), the EMFF and the Cohesion Fund the ceiling thus applies at the level of the priority axis/Union priority. For the ERDF and CF, in the case of a priority axis covering several categories of regions, the ceiling is to be applied to the allocation to the category of region concerned of that priority axis, not to the total allocation of the priority axis overall.

Where an operation is jointly implemented by several Member States (e.g. setting up a Baltic Sea Region research centre which is financed from the Investment for Growth and Jobs programmes in several Member States/regions), the expenditure under the programme of the Member State in which the research centre is located would be eligible in accordance with Article 70(1) CPR (i.e it is considered to be located within the programme area). Programmes in other Member States/regions should contribute on a pro rata basis, with their contributions counting towards the ceiling established in Article 70(2)(b) CPR.

Moreover, taking into account the definition of the operation provided in Article 2 (9) CPR, such operation may a) either take the form of separate operations under each programme or b) considered as one single operation to be included in the programme of the Member State where the research centre is located and to which programmes of the other Member States could contribute to. In all cases, in accordance with Article 65(11) of Regulation (EU) No 1303/2013 the expenditure declared for each expenditure item shall not receive support from another Fund or Union instrument or support from the same Fund under another programme.

(1) Specific provisions for programmes under the ETC Goal are contained in Article 20 ETC Regulation, Article 70 CPR does not apply.
Question 3: Can National Contact Points be co-financed from ESIF for the tasks they might carry out for ESIF programmes?

First of all, it should be stated that cohesion policy is an investment policy which co-finances projects or groups of projects within a national or regional programme. Operations selected under a programme shall therefore contribute to the achievement of the strategy of the programme and of its related priorities. In this respect, it is important to determine whether what is proposed to be financed (i.e. the activity of National Contact Points) is an operation that contributes to the objectives of a priority of an OP and if so ensure that it is selected in accordance with the selection criteria.

Moreover, operations co-financed by ESIF Funds must fall under the scope of the relevant regulation. In this respect, it should be checked whether what is requested to be financed may constitute an operation that falls under the scope of Regulation (EU) No 1303/2013.

In addition, it should be underlined that, where, only part of the activity of National Contact Points may fall under the scope of Regulation (EU) No 1301/2013, a pro-rata financing under ESI Funds should be applied.

Finally, were National Contact Points to be financed from technical assistance, Article 59 CPR requirements should also be respected.

Under the above mentioned conditions, National Contact Points maybe financed from ESI Funds.

The National Contact Points are not paid from Horizon2020 budget concerning their activities related to it. They might be set up within national ministries or agencies or private consultancies. Please refer to the guiding principles for setting up an NCP, published by DG RTD on the Horizon2020 website.
Question 4.1: The Synergies guide states that in case of a project funded by ESIF-Horizon2020 synergy, the capacity to link exact costs to project will be necessary. How will this be possible in case the project uses simplified methods like unit costs or flat rate? Does it mean that in case of synergy projects those methods could not be used?

Bearing in mind that the principle to remind here is that of no double funding, the use of simplified forms, the use of simplified forms of costs or grants (simplified methods, i.e. based on unit costs, lump sums and flat rates) is completely possible for "synergy projects". Indeed, as a general rule, simplified methods may only be used if the categories of eligible costs covered by the concerned unit cost, lump sum or flat rate are clearly identified ex ante (see Article 124(2)(b) of the EU Financial Regulation) for simplified costs used under programmes implemented under direct management, in particular Horizon 2020 and Article 67 of the Common Provision Regulation (CPR) for simplified costs used under ESIF).

Therefore, the requirement for synergy projects that no cost item or expenditure item is declared twice as eligible may also be met for grants based on simplified methods. This simply means that no cost falling within the categories of eligible costs covered by the unit cost, lump sum or flat rate applicable to the programme implemented under direct management may be included in the request for reimbursement under ESIF, and conversely. The underlying rationale is quite similar to that explained under Article 67(3) CPR regarding combination of different forms of grants.

As an example, one R&I project may be funded by two grants based on simplified methods: one grant awarded under Horizon 2020 in the form of reimbursement of direct personnel costs of researchers declared on the basis of unit costs and one grant awarded under an ESI Fund in the forms of a lump sum for the direct costs of infrastructure and flat-rate financing for indirect costs.

Question 4.2: Horizon2020 uses different expense reporting methods than ESIF. In case an Operational Programme takes over a project not funded in Horizon2020, will this project have to follow the OP rules and expense reporting?

This is correct.

Question 4.3: At the moment Horizon2020 and ESIF use different information systems/databases. Managing Authorities can not eliminate possible double funding, as they do not have detailed information about Horizon2020 projects. Will it be possible to share information about particular projects or connect ESIF information system with Horizon2020 system?

Horizon2020 is working directly with final beneficiaries, so the costs claims are not public, even other participants of Horizon2020 can not see them. However the relevant authorities following Horizon2020 in the Member States (at national level) have access to the Common Research Data Warehouse online (over the Internet, for free: CORDA). So the Horizon2020 funded projects can be scrutinised by the authorities, especially when there is a claim by applicants for additional funding by the ESIF; however this information is not public. Connecting IT systems is overly complicated but the authorities at national level can work to share information available.

As stated in chapter 2.1 the EC services strongly encourage synergies through bringing together Horizon2020 and ESIF money in the same project. Eligibility rules for Horizon2020 differ under Horizon2020 depending on the project formats (see section 2.2.1 of the synergies guide), moreover these rules differ for ESIF as well as for state aid schemes. It is not clear, whether financing of ineligible costs for ESI Funds (or state aid scheme) through Horizon2020 (for instance VAT) within the same project will be considered by the EC side as circumventing of the conditions if this procedure had been followed.

The scope of synergies is to increase impact when using EU public funding, exploiting complementarities while at the same time avoiding overlaps and excluding double-financing. There can be no substitution of national or regional or private co funding to projects or programmes by money from other instruments. The eligibility of a cost item will depend on the rules of the instruments where this cost is claimed.

Question 5.1: How shall we take over quality projects that were not funded by Horizon2020? What is exactly meant by the term „reorientation of project"?

Well evaluated proposals (over the threshold) but not being able to be funded (due to budgetary constraints in Horizon2020) could be presented through DG REGIO to the relevant managing authorities for consideration of support by the relevant Operational programmes and only if the applicants in these proposals agree with the process. DG RTD is currently examining the details for launching such an option in more standardised format in the future. By ‘reorientation' the Commission services wanted to stress that, since the majority of the Horizon2020 proposals are transnational, the ‘project' if funded by the ESIF, could not be exactly the same, because the emphasis would then be on only one particular project component / work package that can be supported by only one country (at the time).

Question 5.2: In case a project is taken over from Horizon2020 to be funded by an OP, will it be necessary to evaluate this project at the ESIF level (even in a simplified way) or shall we take over the evaluation from Horizon2020 as it is?

In such cases, the Commission will only provide a suggestion to the MS and the MA: it is then up to them to re-decide how to proceed (no automatism and no obligation for the ‘receiving end' to fund anything). And of course proposals can be re-assessed in the light of the nature and the philosophy of the relevant OP. Nevertheless the fact that the proposals were already evaluated at EU level must provide the necessary quality assurance to the MA (but again there is no automatic obligation for funding by the OP).

Question 5.3: We would welcome to get a practical guide from EC, that would describe specific procedures on how to take over the projects, and use the evaluation from Horizon2020 etc. This guide would be very useful for audits and other controls.

The Commission services will be preparing guidance on this matter. However please see previous answer.

Question 5.4: In case a succesfull Horizon2020 project was taken over by OPxxx, we can assume that this project would have to be modified, to meet OPxxx rules. In case of any change in the project we cannot take over the quality evaluation and the project needs to be evaluated again. Shall we use the HHorizon2020 evaluators who did evaluate the original project (because of efficiency)? If so, who will pay this evaluation (ESIF budget or Horizon2020 budget)?

No obligation on anything described above, please see previous answers.

Question 5.5: In case a project is funded by both ESIF and Horizon2020 at the same time, what will be the implications in terms of monitoring system (different for ESIF and Horizon2020)?

Each instrument will follow its own rules and no changes to them will apply. If a project part is funded by Horizon2020, Horizon2020 rules will apply for this part etc.

Question 6: Who is authorized to provide Horizon2020 project details to a Managing Authority (MA) in case that MA needs information (e.g. qualitative evaluation of the synergy project from Horizon2020; information on whether the project was funded from Horizon2020 or listed in the reserve list – ie. projects above threshold, but not funded-; budget/eligible expenditures, summary report or other relevant documents). MA may need this information to achieve synergies between Horizon2020 and ESIF, for example when taking up high quality proposals that were not funded under Horizon2020, or implementing successive project from Horizon2020 and ESIF that built on each other. Some of this information is available for Program Committees members, but normally confidential and limited.

The Commission services will provide guidance on this point, as part of a standardised future business process.

Question 7.1: State aid rules do not apply to Horizon2020. If a successful Horizon2020 project is to be funded by ESIF, the Managing Authority (MA) will have to apply state aid rules and the project will have to clearly state the nature of activities. That will change the financial support of the project and may have further impacts. To what extent could the project be changed with regards to state aid rules in order to be financed directly, without the whole procedure from ESIF? The project will obviously change because of application of state aid rules unless the rules are not applied.

When this given project will be taken over by ESIF support, ESIF rules will apply for the part of the project funded by ESIF (including compliance with State Aid rules). In any case no Horizon2020 signed Grant Agreement can be modified because of ESIF support, and thus any support from the ESIF should be an additional one, for additional workpackages (not funded by Horizon2020 already !!)

Question 7.2: Where to find more information/ FAQs on State Aid?

DG REGIO organized on 27/1/16 a Thematic seminar: State Aid in Research, Development and Innovation (RDI) projects co-financed from the European Structural and Investment Funds (ESIF).  The seminar webpage includes: 

Question 8: Is it possible to interconnect IT administration systems of Horizon2020 (or Erasmus+) with those of MA for needs of synergies?


Question 9: In view of the fact that funding of complementary/ parallel projects, or combined funding is highly recommended in the Synergy guide, we would welcome if the Commission informed Member States about scheduled plan of calls and indicative plan of interventions of EU programs in advance enough.

All Horizon2020 Call plans are published on the Internet (on the Research & Innovation Participant portal)

Question 10.1: According to the EASME manual, the European Entreprise Network (EEN) will be providing mentoring and coaching services under Horizon2020. Each region has a limited number of „packages for companies" which means a limited number of financial resources. Is it possible to finance these services also from ESIF funds (in the case of using up EEN financing)? If not, is it possible to involve EEN coaches to national or regional projects for mentoring and coaching (financed from ESIF)?
  • Please apply again here the principle of avoidance of double funding. If a Member-State deems that the EEN offering could benefit from additional funding from ESIF sources, this can certainly be considered, but practical implementation would then have to be at the level of the MS; it is not possible to shift ESIF budget directly to EEN at the EU-level, let alone to relevant Member States members, as decisions on budget distribution at EU level have been set legally in the context of the Multi-Annual Financial Framework (2014-2020).
  • In principle, the coaching database will only be accessible by dedicated key account managers (KAMs). For data privacy and confidentiality reasons, access to national or regional authorities will not be provided, in any case not in the short run, which means that the answers to the two latter questions are negative.

Question 10.2: Regarding subsequent cooperation of EEN with project applicants in Horizon2020 / COSME after they were evaluated as ineligible. If the project is not successful, subsequent cooperation e.g. on improvement of project proposal or consultation of further steps is not financed from EEN resources. What way of ensuring financing for these services would be the best? Is it possible to cover these EEN services from ESIF funds? (We consider this as suitable as for the continuity and knowledge of project proposal). Is it possible to finance the training of EEN experts and at the same time of experts under national and regional advisory services projects from ESIF funds?
  • The Enterprise Europe Network (EEN) is not there to perform proposal checks or re-draft proposals, but can point to alternative possibilities for applying for funding at the EU level if the applicant is interested.
  • EEN is financed by COSME and Horizon2020, but not from ESIF (nor can it be); an overview of all prospective EEN services can be found in the call for proposals (see pp. 4-5).
  • If national or regional authorities want to offer more services than the ones already covered at EU level, they are of course welcome to do so.
  • Official EEN trainings will be offered by EASME; at present the inclusion of other experts via ESIF has not been foreseen, as the Network has a limited scope and resources, outlined in the call for proposals.
Question 11: What are the key factors the Commission will be looking at later so as to evaluate if the RIS3 strategies would have been successfully implemented?

There are various criteria to assess the success of RIS3 implementation. Although this success should first be illustrated into the alignment of implementation measures with the RIS3 priorities, it can also be evaluated against a set of less stringent criteria such as the continuation of the stakeholder involvement and the "vitality" of the RIS3 governance.

[1] Alignment of implementation measures with the RIS3 priorities:

In this respect we should distinguish between different cases. Formally, RIS3s have to concentrate resources on a limited set of priorities. What are such priorities is defined in Art 2(3) CPR. In addition to this concentration of resources, there is also scope for horizontal/ generic innovation support within existing RIS3 strategies. The balance between generic vs. concentrated support differs in Member States and regions:

  • Case A: In some MS/regions, most of R&I support sits outside the RIS3 (and outside the ERDF OP (e.g. in Western DE), or outside TO1 (e.g. a lot of regions pushed much of the SME innovation support into TO3 or TO2 and thus legally speaking outside TO1's RIS3 applicability). They opted in the sense of Art 2(3) CPR for "smart specialisation strategy [is…]… included in, a national or regional research and innovation (R&I) strategic policy framework". In this case, ALL of the ERDF-TO1 resources should be used for the RIS3 priorities, and nothing for the generic support.
  • Case B: In other MS/ regions, the RIS3 is the only innovation policy strategy, i.e. in the sense of Art 2(3) CPR "smart specialisation strategy [is the]… national or regional research and innovation (R&I) strategic policy framework ", and also TO2 and TO3 innovation support are made subject of the RIS3 alignment. In this case, the generic support outside RIS3 priorities is allowed. The same goes for regions/countries where there is a need to catch up on very basic issues like the need to build up general innovation capacities (eg. skills, entrepreneurship capacities, etc) when there is not enough non-ERDF (e.g. ESF) funding available.

Taking into account the above distinction, the key element for evaluating the alignment of implementation is whether the calls/ interventions under ERDF-TO1 are exclusively targeted to RIS3 priorities (case A), or specifically targeted to RIS3 priorities (>=80% of resources, case B). This translates into the following conditions (they may be considered jointly or in alternative, depending on how priorities are defined):

  • Measures address only potential beneficiaries that fall explicitly in the categories (typology of actors, economic activity, geographical area, e.g. rural vs. urban) used for the definition of priorities.
  • Measures only fund projects that have in the object activities/ processes that contribute directly to the specific objectives / expected changes associated to each RIS3 priority. In this case, it is recommended that the applicants are compelled to make explicit how their project will contribute to the specific objectives / expected changes associated to each RIS3 priority.

Important implication:

  • It is fundamental that regions/ MS make explicit in the strategy (or in the implementation documents/ calls) what are the specific objectives / expected changes associated to each RIS3 priority. This can be viewed as a (the) way to sharpen priorities.

For regions/ MS under case B, the evaluation on the alignment of ERDF-TO1 implementation with RIS3 priorities cannot be performed on individual calls or any other single implementation procedure. It has to take into account ALL measures already implemented as well as those foreseen for the future, and make sure that a substantial (indicative >=80%) portion of funds is addressed to RIS3 priorities. In this case, it is fundamental to receive from regions/ MS a detailed, though indicative, spending plan that distinguishes between the two types of support.

[2] RIS3 as a continuous process

In this respect, a set of factors is to be considered, like for instance:

  • Continuous stakeholder involvement through stable mechanisms (e.g. organization of recurrent meetings for the discussion of intermediate results); progressive institutionalization of Entrepreneurial Discovery Process through stable formula.
  • Mid-term revision of the strategy with possible change in the priority set.
  • Organization of a mid-term public event for sharing the state-of-art of strategy implementation with a large audience of Quadruple Helix representatives.
Question 12: What is the ‘Governance in Smart Specialisation' based on the ‘Learning Journey' undertaken by ten regions in the SmartSpec FP7 project?

The "Learning Journey" in SmartSpec is a series of dialogues between the project's researchers and ten associated regions (in the form of meetings in each of the regions). It is closely connected to another WorkPackage in the project on Living Laboratories, which are basically regional case studies. They include the ten regions in the "Learning Journey" + 6 others. The results of this are not published, but a summary was presented at the last Mirror Group:

  • Broad based innovation policies: too strong focus on STI policies, underrepresentation of DUI policies in some regions (the Doing-Using-Interacting Approach); consideration of non-technological innovation, service innovation, public sector innovation, social innovation as key future challenge
  • Involvement of non-policy stakeholders in smart spec policy processes: clear evidence for inclusive approaches; need to solve challenges related to vested interests, empowerment, institutionalisation of collaboration
  • Selected priorities for policy intervention: reflect modernisation of existing economic strengths (path extension) & support for emerging activities (path renewal & creation); but in some regions: too wide priorities (no ‘real' prioritisation) & neglect of cross-sectoral activities based on related variety and combinations of knowledge bases
  • External connectedness: creation of links with capacity and capability outside the region is not a widespread phenomenon
Question 13: What are the opportunities for Interreg-Europe and especially on the future role of the "Learning Platforms"?

As the ESIF comes with a number of ex-ante conditionalities that have to be dealt with in regions and Member States across Europe more or less in parallel, the potential for joint actions and mutual learning is enormous and even needed.

This constitutes a great opportunity for Interreg-Europe to reinforce the core European policies for regional development by strengthening the transnational and inter-regional collaboration within R&I, competitiveness, energy etc.

This will not only strengthen ERA and create more opportunities for companies being connected to a larger European knowledge base, but it represents an opportunity to contribute to the production of knowledge and collection of experiences on how to make for instance Smart Specialisation a success both at regional, national and European level. The planned "Policy Learning Platforms" are meant to ensure in a structured way that lessons are drawn from valuable experiences, codified and shared with the whole European community. This contributes again to sound and informed investments of ESIF and increases the chances of positive results for growth, employment and reduction of emissions.