European Structural and Investment Funds: preparing for closure – best practice guide and key deadlines

Closure operation - technical aspects

You should consider creating an operation archive for your operation. The operation archive should include the location of key records and documents relating to your operation activity and if records are kept on different media and in other locations, the archive should indicate the access to these and where these records are located for future inspection. The operation archive should include your business plan and the evidence presented to the Managing Authority to support your business plan, Offer of Grant letter (and any subsequent variation of grant letters which amend the offer of grant) along with any letters of decision from the Managing Authority particularly around decisions arising from eligibility queries.

It should include (but not limited to):

• completions certificates i.e. final building certificates, BREEAM assessments
• beneficiary records
• procurement records
• financial records
• timesheets etc.

The archive should include an assets register/inventory detailing the assets purchased and the location for future audits and monitoring visits, a copy will be required as part of the closure process. Strategic Intervention (SI) and operation managers should check that the operation asset register is up-to-date and, at a minimum, includes all items with an initial cost/value above £5,000. The inventory/register must include all operation assets, even if located within/acquired by a partner organisation.

Organisations who operate a policy of recording lower value items in their asset registers should follow their own threshold.

Inventory of assets

The operation Lead Partner is responsible for establishing and maintaining an inventory of all assets with a value greater than £5,000 whether owned by the operation Lead Partner or a third party.

The inventory should show the:

• date of purchase of the asset
• description of asset
• price paid net recoverable VAT
• amount of grant paid
• location of the title deeds
• serial or identification numbers
• location of the asset
• date of disposal
• sale proceeds net of VAT

Document management and retention

Lead Partners are responsible for maintaining adequate records (IT, paper, and other recording media) to fully document all operation records, including financial and accounting records and for making them available, as required, to the Managing Authority and to auditors. Failure to provide supporting documentation relating to European Structural Funds activity will result in a clawback of grant funding. This means retention until at least 2027, but the Lead Partner must retain all documents until the Managing Authority advises otherwise.

Records management policy and the Managing Authority guidance

Your operation must have a document management policy. The policy should include storage instructions, retention dates and provide details of any protocols for management of sensitive data. It should also provide details of the location of documents especially in circumstances where the operation Lead Partner is working with a delivery agent and/or where an operation has procured services and the records are not being kept by the Lead Partner. Where records are kept electronically, they should be available in a form that can be fully retrievable for the retention period set out in guidance. This should form part of the operation archive.

It is important to remember that the Lead Partner is responsible for the retention of all of the records for an operation, so the policy should also detail the systems in place for the retrieval of those records/documents from a third party contractor in circumstances where they are unable to keep the records/documents. Where the Lead Partner cannot obtain a guarantee of this from other parties the Lead Partner must retrieve all records for retention and audit purposes. This remains the case post-operation closure until the end of the retention period for 2014-2020 programmes or until notified by the Managing Authority.

Operation management records

A final review should be undertaken on your operation management records and they should form part of your operation archive. As well as including the evidence to show how the operation was managed (minutes of meetings, operation governance) the archive should include the financial records such as original invoices and electronic financial records to evidence your activity and expenditure. The archive should also include evidence of operation monitoring such as:

• full audit trails of actual costs
• match funding
• in kind match
• staff recruitment and job descriptions
• other appointments
• timesheets and evidence of pay rates used and the employers BACS payment and a bank statement to support this transaction
• evidence of unit cost methodologies applied (excluding the Employment Related Counselling Service unit cost) and the agreement by the Managing Authority should also be retained
• evidence of any apportionment methodologies applied (for example, percentage split using floor space, percentage split of programme/location) and the agreement by the Managing Authority should also be retained

State aid

Lead Partners also need to consider any additional requirements (including extended retention periods) that may be required relating to operations involving an element of state aid – not only will you be required to keep records for the retention period of the programme, but as the state aid record retention period is normally 10 years from the date on which the last individual aid was granted, this period could extend beyond the period generally applicable to operations (three years following the formal closure of the Operational Programme) and therefore records relating to aid must still be retained until the state aid record retention period has elapsed.

Procurement

You should ensure that all your contracts have been completed, have been added to the relevant page on EUMIS and indicate they are now closed by the Procurement Team within the Managing Authority. Lead Partners should ensure that all records relating to procurement are available for the retention period set out by the Managing Authority and where records are kept by a third party (contracted service) the Lead Partner should satisfy themselves that those records will be available for the scrutiny by audit for the same period. This should include records relating to the activity and monitoring.

Publicity/marketing

You will need to ensure compliance with ESIF publicity requirements by retaining evidence of the publicity measures undertaken for your operation. For both European Social Fund (ESF) and European Regional Development Fund (ERDF) operations you will be required to provide evidence of compliance by placing a plaque in the reception of the building or in a prominent location relative to the operation activity.

For capital/infrastructure operations, such as the construction of a road, a building or physical regeneration, photographic evidence is required in your operation archive of any signage/billboards erected during works.

Evidence should also be included in your archive of other operation publicity, which should also feature the ESF/ERDF logo e.g. press releases, website/digital content, and copies of marketing publications (leaflets, newsletters, promotional materials, stakeholder’s reports to any non-Scottish Government audience etc.).

There might be instances where your operation could be used as a good or best practice example for visits by Scottish Ministers, the EC or other Member States. If your operation is selected the Managing Authority will inform your organisation to enable preparation for these visits.

Your operation will likely be holding events to celebrate operation achievements, to disseminate reports, advertise the websites, etc. during the final months so it will be helpful for you to contact the Managing Authority Communications Manager to advise them of any key or large-scale events. You can do this via email to: europeanstructuralfunds@gov.scot