The Leviathan Confederation took part in the consultation of draft amendments to the Guidelines on the eligibility of expenditure for the period 2021–2027. This paper is crucial for the implementation of projects financed by European funds, as it lays down rules on the bearing and accounting of expenditure by beneficiaries and procedures for the acquisition of services and supplies in projects.
Improving the competitiveness threshold
Although specified a proposal did not come from the Ministry of Funds and Regional Policy, Leviathan, in his comments to the guidelines, highlighted the request to rise the threshold of application of the rule of competitiveness to PLN 170 000.
According to the Confederate Leviathan, the current threshold (PLN80,000) is besides low in relation to the reality of the implementation of projects financed by EU funds. In practice, this means that formalised purchasing procedures must besides be carried out for contracts of comparatively small value.
This creates a number of problems in implementing projects:
- extending the time of execution of purchases and full projects,
- increasing the administrative burden on beneficiaries,
- the request for extended documentation with tiny orders,
- increased hazard of procedural errors at the same time a tiny scale of procurement.
– Unifying the threshold to PLN 170 thousand, i.e. to the level of the public procurement system, will increase the consistency of the regulatory strategy and reduce the excessive administrative burden. At the same time, the transparency of public spending will not be adversely affected," says Agnieszka Lewandowska, expert of the Leviathan Confederation.
Comments on the proposed amendments
The comments made by Leviathan besides mention to the changes proposed in the draft guidelines. 1 of the key elements of the amendment is the introduction of rules on task implementation in synergy with programmes straight managed by the European Commission, specified as investigation programmes or innovative programmes financed from EU level.
– We are positively assessing the direction of these changes, as synergies can increase the efficiency of European funds and facilitate the pooling of different sources of task funding. We have already highlighted problems in implementing any of these projects (e.g. European Digital Innovation Hubs – EDIH – implemented in the FENG programme) as a consequence of restrictive interpretations of cost eligibility. The backing rules at EU and national level were divergent. Addressing this issue by changing the provisions of the guidelines is so beneficial. However, we draw attention to the request to clarify any of the provisions so that they are unambiguous and do not rise any doubts about the implementation of the projects in practice," added Agnieszka Lewandowska.
A broader revision of the guidelines is needed
The proposed draft revision of the guidelines on the eligibility of expenditure covers only a narrow set of rules. According to the Confederate Leviathan, it is essential to review the existing provisions regularly and to adapt them to task implementation practice. A re-examination is justified in the light of the experience of the implementation of the programmes in the current financial perspective, both on the beneficiary side and from the position of the institutions liable for implementing the funds.
Businesses indicate that certain regulations require clarification or simplification, to reduce excessive administrative burdens and increase transparency of task implementation rules.
Simple language in programming documents
The Confederacy of Leviathan besides points out the request for greater application of the principles of simple language in the guidelines. European fund managers are increasingly promoting the usage of clear and understandable language in communication with beneficiaries. According to entrepreneurs, this rule should besides be applied in systemic papers specified as guidelines. This means, above all, utilizing shorter sentences, a clearer text structure and reducing the number of complicated legal wordings. specified an approach would facilitate the explanation of the rules and their correct application by beneficiaries implementing projects financed from European funds.
Our position here
Confederation of Leviathan
