European Structural and Investment Funds: document retention guidance

Third party document retention

3.1. Records and documents not held on the Lead Partners' premises.

Accounting records and supporting documents could be held by:

• Lead Partner (Lead Partner or Delivery Agents); or
• third party delivery partners such as procured contractors/service providers

3.2. Where records are held at locations other than the Lead Partners' premises – such as off-site storage facilities or the premises of partners and service providers/contractors – then the Lead Partner must satisfy themselves that storage is in line with the expectations of this guidance, such as:

• records are retrievable and accessible
• partners/providers allow full access to records at their premises, including where applicable, access to view ‘born digital’ or digitised records using a suitable ICT device or workstation
• records are complete; structured and well-organised; in good condition
• in an acceptable format that meets MA requirements

3.3. In the absence an adequate audit trail, or the inability to access records during audits and verifications, this could lead to the associated expenditure being declared as ineligible with a corresponding reduction in EU grant, whether the problems arise through the Lead Partners own actions, or that of a partner/provider.

Examples of good practice for third party document retention management include, but are not limited to:

• a record of regular spot-checks performed on partner organisations, including details of any remedial action taken when the results of the spot-checks prove unsatisfactory
• where it is clear that partners/providers are not able to satisfy these standards, all records are transferred and held by the Lead Partner
• where the Lead Partner considers it necessary, they should also consider requiring the transfer of original documents at the time that Delivery Agents/providers submit their invoices or expenditure declarations
• photocopies, scanned images and digital records held by partners/ provides remain subject to the usual safeguards on authenticity
• similarly, where the Lead Partner is informed, or suspects, that a partner/ provider may shortly cease trading (close down, dissolved, liquidation etc.) or other imminent event that may impair the ability to comply with all record-keeping requirements, it must arrange for the records to be transferred and held at its own premises