Checks, audits, reviews & investigations
In order to ensure sound financial management and compliance with the Grant Agreement rules, the Granting Authority will perform project reviews and financial audits on participants.
For lump sum grants, since they do not use actual costs, there will be no financial audits focusing on costs. Reviews will focus on the technical implementation of the action or other aspects of the Grant Agreement.
The Granting Authority will regularly monitor the project implementation and check the proper implementation of the action and compliance with the Grant Agreement obligations, including assessing deliverables and reports.
In addition, the Granting Authority may also carry out in-depth project reviews. Those reviews focus typically on the technical implementation of the project, but may also cover financial and budgetary aspects or compliance with other obligations under the GA.
In addition, most programmes perform financial audits of participants in EU projects (often with the help of outside audit firms).
Such audits will be performed in accordance with International Standards on Auditing. The auditors comply with ethical requirements and will plan and perform relevant procedures in line with the EU Grants Audit Manual, in order to obtain reasonable assurance that the Financial Statements are free of material misstatement.
You will receive a draft audit report on which you will be able to provide your observations.
If systemic errors are found, the Granting Authority may extend the findings of the audit results to non-audited Grant Agreements or non-audited periods.
Anti-fraud strategy — OLAF investigations
In case of fraud suspicions, the Granting Authority will inform the European Anti-fraud Office (OLAF), who may conduct more in-depth investigations.
OLAF also cooperates with national authorities (through information exchange, on-the-spot checks, coordination of forensic audits etc.)
Certificate on the methodology for unit cost (CoMUC)
The CoMUC is a factual report produced by an independent auditor (using the template available on Portal Reference Documents). Its purpose is to enable the granting authority to:
- identify your usual cost accounting practices
- check that you have used a suitable unit cost accounting methodology.
Submitting a CoMUC methodology certificate is voluntary. Doing so will help prevent problems later on, if your grant is audited. If the certificate is approved, costs declared in line with this methodology will not be challenged, unless you have concealed information for the purpose of the approval.
For the MFF 2021-2027, only CEF and Digital Europe will be using this certification. For Horizon Europe it has been replaced by the SPA (systems and process audit; see AGA — Annotated Grant Agreement, art 24).
The certificate may be requested at any time during the implementation of the programme.
As a minimum, one project should have been started and the data available must give the auditor enough of a basis to carry out the necessary procedures. Ideally, we would recommend submitting the methodology after at least one reporting period has passed.
In case of subsequent changes to your methodology you should notify the Granting Authority. You may also submit a new certificate reflecting the changes.