Yorkshire and Humber ERDF Programme Document Retention Records to Keep

Transcription

1 Yorkshire and Humber ERDF Programme Document Retention Records to Keep Title Document Retention Records to Keep Version 1 Status Date created Author LC Date of Issue Next review date Author Final Version Agreed by: Adrian Green Date 28 Apr 09 Control access document at: or Docubank 5935 or K:\Yorkshire Forward\Finance Directorate\European Funding\ERDF \Programme Management\Guidance 1

2 Version No. Date Reason for change By who? Include information on electronic GK document retention Amend earliest date to 31 December 2025 GK 2

3 Document Retention Records to Keep 1.1 Why keep project records? It is essential that project records are maintained in order to provide a complete audit trail of evidence that ERDF funds have been managed and expended compliantly with EC rules and regulations. It is also important that project records demonstrate evidence of the progress and achievement of any outputs contained within the Offer Letter. Projects are, potentially, subject to a number of inspection visits from various authorities throughout its lifetime. The purpose of these is to verify that eligible expenditure claimed is consistent with the application (Full Business Plan etc) and Offer Letter and evidence that procurement procedures, state aid and publicity requirements etc have been met. 1.2 For how long should records be kept? Article 90 of regulation EC 1083/2006 states: Without prejudice to the rules governing State aid under Article 87,of the Treaty, the Managing Authority shall ensure that all the supporting documents regarding expenditure and audits on the operational programme concerned are kept available for the Commission and the European Court of Auditors for (a) a period of three years following the closure of an operational programme. The Commission will inform the Member State when the Programme is closed but for guidance purposes it is currently expected that this will be 31 December 2025, at the earliest. You should wait, however, until Yorkshire Forward writes to you with an actual closure date before disposing of your records. You should also expect that the project could be inspected at any time after it has closed and up to the closure of the overall Programme. Upon inspection, auditors will want to see original documentation wherever possible ie invoices, receipts, activity records etc. so please bear this in mind when making any storage or archiving arrangements. A certified signed copy of an original, however, will be acceptable if done so by a senior person within the project applicant organisation. If you are unable to produce auditable evidence, you will have to pay back the appropriate amount of grant even if the project ended years ago. 1.3 Who is responsible? Ultimate responsibility for retention of documents lies with the grant recipient and projects must be able to clearly demonstrate: the creation and adherence to a document retention policy that conforms to EC regulations the retention and availability of source documentation that supports claimed project expenditure and claimed outputs and results to meet the requirements of Article 13 project monitoring, Article 16 project inspections ( or any other national or EC audit) agreed apportionment or overhead methodologies when not based on actual costs and; documentation to support adherence to EC rules and regulations such as publicity, state aid and procurement. The grant recipient is also responsible for any partner or sub-contractor records; this may require a programme of quality assurance work on behalf of the grant recipient to verify the information provided by partners i.e. the organisation in receipt of the Offer of Grant is responsible for the full audit trail. To ensure that partners and sub contracts meet all 3

4 requirements, the terms of the offer letter must be replicated in subcontracts/ SLAs with these organisations. 1.4 What records are needed? Core documentation for the project The Application (Outline and Full Business Plans and any supporting documentation) The signed offer letter and any subsequent amendments Copies of any material correspondence with developers and deliverers in the agency Copies of any agreed changes to the project Match funding documentation Working papers showing how the claims were calculated Beneficiary documentation 1.5 Expenditure You must keep all the original documents that support all expenditure relating to the project including: Internal staff costs salary records, detailed time sheets (to show time allocated to the project) and any agreed apportionment methodologies Other costs: invoices, payment receipts, apportionment methodologies, depreciation methodology, copies of leasing/ hire agreements, source documentation for overheads For second hand equipment you must keep a declaration by the seller stating the origin of the equipment, and that it has not been purchased with the aid of national or EC grant. You must also keep proof that it does not exceed market value or cost of similar new equipment. 1.6 Tendering/ procurement All projects must adhere to the community rules on tendering and procurement (see Procurement Guidance on Yorkshire Forward website). Projects must keep records in line with these requirements. It is very important to be able to produce: Copies of quotations and tender documents Clear evidence of how decisions have been made and by whom 1.7 Inventory of Assets For all assets over 2,500 which have been either bought, built or improved using ERDF grant, inventory must show: date of acquisition description of each asset price paid net or recoverable VAT amount of ERDF grant paid location of the asset location of the title deeds or ownership records (where relevant) serial or identification numbers date of disposal name and address of any person/ business to whom disposal is made sale of proceeds net of VAT 4

5 1.8 Records of match funding and income Should evidence: full transaction listings (in support of claims) details of match funding details of any income received bank statements (also to prove defrayment of expenditure) audited accounts any working papers used in calculations. agreed apportionment rationales (agreed with Yorkshire Forward) 1.9 Project Specific Records You must keep evidence of the eligibility of the project beneficiaries on your project: e.g. SMEs, individuals, large companies (Priority 1 only), Social Enterprises etc Records should be retained pertinent to your particular project - to demonstrate what activity has actually been delivered Publicity records Please refer to guidance on Yorkshire Forward website regarding Publicity. It is important that you evidence any written material you produce, as well as photographs of billboards etc Electronic Only Records Where documents exist in electronic version only, the underlying computer system on which they are held must meet accepted security standards complying with national legal requirements and can be relied upon for audit purposes. COBIT (issued by the IT Governance Institute) or ISO standards on information security provide guidance on suitable standards for electronic systems Non Paper Storage Documents may also be held on commonly accepted data carriers which include; photocopies of original documents; microfiches of original documents; electronic versions of original documents on optical data carriers (such as CD-ROM, hard disk or magnetic disk); documents existing in electronic version only. 5

6 Each document should be certified as conforming to the original using a declaration as per the example below. This is the minimum requirement but may be added to. I certify that this is a true copy of the original document Signed Date Position in organisation Name of organisation. This certification procedure places the onus on the project applicant for ensuring the authenticity of the electronic copy. It may still be a requirement that the document can be retrieved and relied upon for audit purposes. Electronic copies of documents are to be retained for the same duration as required for paper copies. Please note if your organisation closes, goes into receivership or ceases to exist prior to the close of the Programme (estimated 2023) the Agency should be duly informed and all project records should be returned to Yorkshire Forward in an accessible state, for archiving. Equally if a subcontractor or partner closes etc, you must ensure that all their records pertaining to your project are returned to your organisation for archiving thus ensuring you retain access to a complete audit trail for the project. Failure to evidence a complete audit trail will result in claw-back of funding. 6