Please confirm that criterion “B3 Maturity of the project” will be applied only to activities related to equipment and infrastructure, and it will not be applied to activities related to external expertise and services.

As it is stated in Annex 15b “This criterion applies specifically to infrastructure and equipment-related activities.”

Regarding the maturity-related criteria in Annex 15b – Evaluation Grid Phase B2, we noted that: • Projects whose physical content require studies, design solutions, surveys, procurements receive maximum 10 points, and projects that do not require studies or procurement preparation receive maximum 5 points; • Projects requiring licensing procedures receive 5 points, and those who do not require licenses receive maximum 3 points. In the case of a project where: • The Lead Beneficiary implements infrastructure requiring procurement and permits, and • A Project Beneficiary implements only delivery of equipment not requiring any studies or permits, we kindly request clarification on the following: 1. How is the maturity score calculated in this case? o Is the score averaged across all beneficiaries? o Or is one maturity score applied to the entire project based on the most demanding component (e.g. infrastructure)? 2. Would the presence of a Project Beneficiary with no maturity requirements reduce the total maturity score, or is this handled separately for each part of the partnership? This clarification is important to ensure fair expectation-setting across different types of beneficiaries during project planning and application. In projects where certain partners implement infrastructure works or equipment purchases, the scoring of these criteria will be based solely on the maturity level of those specific actions. In such cases, the soft activities of the other partners will not affect the score.

Maturity is assessed at the project level, not at the partner level; therefore, a project beneficiary implementing equipment or infrastructure works without sufficient maturity will impact the overall score.
Annex 15b provides a detailed explanation regarding the scoring methodology for criteria B3a and B3b. In cases where all project partners implement only soft activities (i.e. the project includes exclusively staff costs, office and administrative costs, travel and accommodation costs, and external expertise costs), the scores for these criteria will be 5 and 3 respectively.

I would like to request clarification regarding the State Aid Declaration that must be submitted by each Beneficiary as part of the application package. The statement reads: “In the fiscal year in progress and in the two previous fiscal years the organisation I represent and all other entities belonging to the same company group did not benefit / benefited (as stated below in the table) from De minimis funding.” In this context, we would like to ask: Which database should be used as the official source for verifying the De minimis aid received? Should the information be taken from the BG De minimis Register, the Greek national register on state aid (SOREFSIS), or another specific database designated by the Programme?

Beneficiaries should refer to the official national register of De minimis funding applicable in their country when verifying and declaring De minimis aid. Specifically:
• For Bulgarian entities, the BG De minimis Register should be used. https://minimis.minfin.bg/
• For Greek entities, the relevant source is the Greek national register on State Aid (SOREFSIS).

MIS/ AF/ Additional information/ question 30: Please clarify the meaning of each of the available options: Direct payment/ Indirect payment – Funding / Indirect Payment – Special Account.

Please note that this field is not required at this stage. It will be compulsory in case of approval.
It concerns ONLY the Greek partners and refers to the way the payments are executed, selecting the appropriate value from the available list. More particular:

Direct payment: The payment by the Accountable Entity / Project Officer is made by paying the corresponding amount via e-PDE directly to the contractor’s bank account.
Indirect payment – Grant: The indirect payment – grant shall be made by the Accountable Entity / Project Officer by transferring a credit to the specific blocked bank account of the beneficiary. The release of the funds for making the final payments (payment of suppliers, transfer of credits directly to the beneficiary) shall be made in accordance with the respective institutional framework applicable in each case.
Indirect Payment – Special Account: the payment without an accountable entity is made by transferring credit to a Special bank Account (it concerns Special Accounts for Research Funds of eg. Universities, Regional Health Authorities,..) In case “other kind or combination of payments” is selected, analytical description per each Greek partner has to be provided in the comments.

What date should we enter in MIS as a start date?

At Stage B you can edit the start and end date of the project. You may indicate 01/10/2025 as the estimated start date. This start date is not binding.
In case your project is approved for funding, the start and end dates may be adjusted during the contracting phase, if needed.
In any case, it is crucial that the project duration does not exceed 24 months.

After completing the Application Form on MIS, is it necessary to extract the final AF in PDF, sign & stamp it and upload it on MIS before the submission?

The procedure described above is not necessary. The MIS system automatically creates and restores the final version of the AF in the attachment section.

In the context of completing the Partnership Agreement for the INTERREG Greece-Bulgaria 2021–2027 Programme, we seek clarification concerning Article 4, specifically the requirement for each Beneficiary to confirm its financial capacity and commit the 20% of its project budget as national cofinancing. As per the Partnership Agreement template provided: “Each Beneficiary, in order to fully implement the project deliverables specifically allocated to them, ensures that it has complete financial capacity and, in the case of approval of the project, will commit the 20% of its project budget as national co-financing amount of ……. Euros in total (LB ….. Euros, PBn Euros,) for the above-mentioned purpose.” Considering that, according to the Programme documents, the national cofinancing (20%) is expected to be provided by the respective National Authority following project approval, we kindly ask for clarification on the following points: 1. How should a Beneficiary explicitly indicate in the Partnership Agreement that the required national co-financing (20%) will be provided by the respective National Authority rather than from the Beneficiary’s own financial resources? 2. In case the respective National Authority does not allocate the expected national co-financing amount, will the Beneficiary be obligated to provide this 20% from its own financial resources to remain compliant with the Programme’s financial obligations? 3. Would it be acceptable and advisable for Beneficiaries to include in the Partnership Agreement a conditional statement clearly indicating that the availability of national co-financing is subject to approval procedures and relevant national mechanisms? If yes, could you suggest an appropriate wording?

The Partnership Declaration is signed at the moment of project submission to assure the constitution of the partnership of the proposed project. The text of the Partnership Declaration is to be completed with information without making any modifications in the text.
In case of project approval the beneficiaries have to sign the Partnership Agreement of the project which along with the Subsidy Contract are the binding documents for the project implementation.
In regards to the national co-financing the rules of the Programme refer to public national co-financing received both from Greece and Bulgaria. For more information in this regard please check the Call, the Programme Manual (section Payments/ Cashflows)

In Annex 7, are there any limitation in words on pages?

There is no word limit set by the Call. However, the response should be concise and include all required information without unnecessary detail or wordiness.

Our Project consortium consist of 4 partners, 2 Universities one from Greece, one from Bulgaria and 2 Municipalities one from Greece, one from Bulgaria. Do we have to submit any legal documents such as statutes and any other documentation to prove the legal operation of those partners?

All partners should upload in the MIS system/Utilities 8.1./Body account the needed documents as listed in the above Table (Q.2.16/A.2.16) in accordance to their legal status.

Is there a draft document for the “Declaration for the non-distribution of profits”. This document must be uploaded by each partner, and I couldn’t find a draft in the website.

No, there is no such template. You need to submit a declaration of your own with the letterhead of the organization, signed and stamped by LR., If the relevant information is included in the Organization’s Statute, a separate statement does not need to be attached

The list with all the legal documents that each partner has to upload in the section 8.1 Utilities, is it described in the Annex 16 “Guidelines for applying in MIS 2021-2027”, page 49? What documents do we need to submit for proving Beneficiaries eligibility?

First of all, you need to upload the relevant documents attesting to the Legal Representative’s (LR) power of signature under the MIS BODY CODE of each organisation. Additionally, please refer to the information and table given below.

All partners of the proposed project, the Lead Beneficiary and each Project Beneficiary must attach in MENU “Utilities” section/8.1. Project Bodies Information of the MIS the legal documents that prove the administrative and financial capability, the authority/competency of the beneficiaries for the implementation of the activities of the specific Project, the regulatory framework for the designation of the body responsible for the operation and maintenance of the Project, the existence and operation of a Branch (if applicable)
The legal documents that need to be provided, per category of organization (public, public equivalent, private) are the following:

All the necessary documents can be in the native language of the Beneficiary.
Additionally, the organigramme can be drawn by you, signed and stamped.
Through the above documents it is demonstrated that the participating Beneficiary has the competence/ capacity/ experience etc. to participate in an administrative level at the project but also has experience in the thematic area of the project.

Please clarify in which cases Climate Endurance Validation Report is required and who is responsible for definition of the lifecycle of the infrastructure? If the project envisages only minor internal construction improvements to a building, will it still need Climate Endurance Validation Report?

According to EU rules, infrastructure activities — similarly to immaterial ones — must continue their operation for at least five years after the end of the financing period.
In practical terms, within the context of the present Call, this means that all actions which include expenditure under the budget line Infrastructure & Works fall under the obligation of ensuring a lifecycle of more than five years.
Therefore, all such projects are required to submit a Climate Endurance Validation Report, as they are considered to involve infrastructure with a lifecycle exceeding five years.
Every partner involved in infrastructure works should complete the report of Annex 8- Climate Endurance Validation Report, following the format provided, sign, stamp and attach on MIS in English Language.
In case a proposal does not include infrastructure works, meaning the budget category “Infrastructure and Works” has no budget, a statement of the LB regarding the non-obligation to submit A.8 should be submitted in the relevant document category in the MIS system.

Regarding the preparation of the Climate Endurance Validation Report, required as part of the project application package, we understand from the available Programme documentation (Annex 8) that Beneficiaries must undertake: – Calculation of the project’s greenhouse gas (GHG) emissions, including direct and indirect emissions. – Identification, quantification, and management of climate-related risks. – Assessment of the project’s resilience and adaptation potential to climate change. However, we kindly seek additional clarification on the following aspects not explicitly detailed in the provided documentation: 1. GHG Emissions Calculation: – Are there specific international standards or official data sources (e.g., IPCC Guidelines, EEA emission factors, national inventories) recommended or required by the Programme for performing GHG emissions calculations? – Climate Risk Assessment and Adaptation: Is there a preferred methodological framework or specific risk assessment tool recommended by the Programme for quantifying climaterelated risks and evaluating project resilience and adaptation? – Official Guidelines or Tools: Does the Programme offer or recommend access to official databases, guidelines, methodological references, or other supporting tools to ensure methodological consistency and accuracy? – Providing clear references or recommended methodologies would significantly help ensure consistency and compliance with Programme standards.

The Programme provides applicants with Annex 8, which includes guidelines on how to draft and structure this document.

The Programme does not prescribe or recommend specific methodologies, international standards, or data sources. However, applicants are expected to use scientifically robust and well-documented approaches. Reports and analyses based on recognized scientific principles, international best practices, or validated data sources are considered acceptable, provided that their methodological soundness and relevance to the project context can be clearly demonstrated. 

What specific procurement rules apply to BG non-profit organisations participating as Beneficiaries under this Call? Should they follow the rules under Resolution No. 4/2024, and if so, how should this be reflected in the Project Maturity documentation?

Each Beneficiary must follow the procurement procedures as defined by both European and national legislation applicable to public procurement. The relevant procedures will be agreed upon and finalized between the Beneficiaries and the Managing Authority following the approval of each Project and the signing of the subsidy contract, as part of the Procurement Plan.

While Annex 6 of the Application Form requires the indication of certain expenditures in terms of their maturity, it does not specify the method of procurement. Therefore, for all beneficiaries, the applicable procurement framework will be clarified and confirmed as referred above in accordance with the European and National legislation and the Programme’s requirements.

Please clarify in what language should documents listed in Project Maturity Table, Annex 6 be presented – technical specification, work designs, studies, environmental licence, tender documents, etc. Since these are documents required under the national procurement or construction legislation, it is assumed that they should be prepared and presented only in Bulgarian or Greek language.

The documents listed in the Project Maturity Sheet are expected to be drafted in the respective national language.

1. In Annex 6 ‘Project maturity sheet’ each beneficiary should describe the documents that will be attached to the application form in MIS. Is there a restriction as to who has to sign those documents (for example does the Bill of quantities need to be signed by an engineer)? Is it possible for all documents described in the Maturity sheet to be signed by the project Manager? 2. The Maturity sheet table contains cells entitled ‘Approval number’ and ‘Responsible body for approval’. Who is expected to approve the documents? (For example who is expected to approve the Technical specifications?) Is there any template for the technical specifications for the equipment and what kind of details should they contain? 3. In case of infrastructure works – what is expected to be included in the Operational/ Maintenance section?

1. Signatures on documents listed in Annex 6 – Project Maturity Sheet

In order for the documents listed in Annex 6 to be considered valid and acceptable, they must be signed by the competent authority or person, depending on the nature of each document.
For example, technical studies must be signed by the responsible engineers or technical experts who prepared them, and they must also be officially approved or endorsed by the relevant governing body of the Beneficiary, in accordance with the organisation’s statutes/internal procedures or applicable legal framework.
Signing technical documents solely by the Project Manager is not acceptable, unless the Project Manager is also the legally designated and qualified authority for that specific document type.

2. Approval of documents – “Approval number” and “Responsible body for approval” in Annex 6

Each Beneficiary must follow the internal procedures set out in their governing statutes and relevant national legislation to determine which body or authority is responsible for approving various project-related documents.
For example, technical specifications or studies may need to be approved by a Board, a Technical Council, or another designated internal authority depending on the structure of the organisation.
At this stage, there is no specific template provided by the Programme for technical specifications for equipment. However, such documents should include at minimum:
– A clear and detailed description of the equipment
– Technical parameters and performance criteria
– Estimated quantities and indicative costs (where relevant)

3. Operational/Maintenance Section – Infrastructure Projects

In the case of infrastructure projects, this section should clearly identify the entity responsible for the operation and maintenance of the infrastructure after the completion of the project and the end of the funding period.
In most cases, this will be the Beneficiary itself. However, there may be exceptions, such as when a different organisation or public utility is formally assigned the responsibility for operation or maintenance. In any case, the Beneficiary is expected to provide this information, based on the project’s type and applicable administrative arrangements. Moreover, the documents  concerning the Regulatory Framework for the Designation of the Body responsible for the operation and maintenance of the Project (in case of infrastructure works) must be attached in MIS/Utilities 8.1 Project Bodies Information/ Body Account

Regarding the Annex 6 – Project Maturity Sheet • Please clarify if the deliverables should be grouped in the table per tender procedure. • In the following requirement, please clarify what the 2 acronyms stand for: “Letter from the environmental body specifying that such EIA and AA is not required” • Please clarify where is section A6 that is mentioned in the last page: “…….then the relevant information should be completed in Section A6”

The scope of this document is to demonstrate the maturity of the tenders that are to be conducted as part of the project. In the event that there are common activities across different deliverables which together exceed the above limits and a tender will be conducted for their assignment, then the relevant information should be completed in Annex 6.
Given that, in the event that the budget of a deliverable per cost category (i.e., external expertise and services, equipment, infrastructure) exceeds the previous limits but the expenses pertain to not similar deliverables whose individual budgets do not exceed the set thresholds, then Annex A6 does not need to be filled in for these expenses.

The acronyms mean: EIA – Environmental/Ecological Impact Assessment and AA -Appropriate Assessment / They refer to documents applicable for Bulgarian Beneficiaries

In Annex 1: Partnership Declaration there is a text “ 6. Each Partner, upon signing this current declaration, confirms that a) the activities of the proposed project have not been completed by the date of submission of the application for funding in accordance with Regulation (EU) 2021/1060 (Article 63 9) & EU (1059/21 (Article 22 4f). However, part of the activities can and should be completed upon signing of the declaration – for example, preparation activities related to work designs, etc. Please confirm that this text will not apply to completed preparation activities.

The project eligibility period starts with the signature of the Subsidy Contract and lasts until the end date of the project.
However, in case project activities started their implementation before the signing of the Subsidy Contract—and in any case after 01/01/2021—they should not have been concluded before the application for funding at STAGE B of this Call, in order to be eligible. An exception to this rule applies to preparation costs, which are eligible even if concluded before the application.

Annex 16 “Guidelines for applying in MIS 2021-2027″/ p. 47 -Annex A: a. Please clarify the documents that have to be submitted by each of the following: “Public Bodies”, “Bodies governed by public law” and “Bodies governed by private law/ NGOs” b. Please clarify what documents should be submitted in the following categories: – Financial Capacity – Category: 03. Documents providing evidence for the beneficiary’s competence. – Category: 08. Regulatory framework for the designation of the body responsible for the operation and maintenance of the project – Declaration for the non-distribution of profits (Is there a template to be used? If not, should the partners draft their own? / Is this Declaration mandatory to be submitted by “Public Bodies” or “Bodies governed by public law”?)

According to EU rules, infrastructure activities — similarly to immaterial ones — must continue their operation for at least five years after the end of the financing period.
In practical terms, within the context of the present Call, this means that all actions which include expenditure under the budget line Infrastructure & Works fall under the obligation of ensuring a lifecycle of more than five years.
Therefore, all such projects are required to submit a Climate Endurance Validation Report, as they are considered to involve infrastructure with a lifecycle exceeding five years.
Every partner involved in infrastructure works should complete the report of Annex 8- Climate Endurance Validation Report, following the format provided, sign, stamp and attach on MIS in English Language.
In case a proposal does not include infrastructure works, meaning the budget category “Infrastructure and Works” has no budget, a statement of the LB regarding the non-obligation to submit A.8 should be submitted in the relevant document category in the MIS system.

To prove the Beneficiaries eligibility you need to upload the relevant documents attesting to the Legal Representative’s (LR) power of signature under the MIS BODY CODE of each organisation. Additionally, please refer to the information and table given below.

All partners of the proposed project, the Lead Beneficiary and each Project Beneficiary must attach in MENU “Utilities” section/8.1. Project Bodies Information of the MIS the legal documents that prove the administrative and financial capability, the authority/competency of the beneficiaries for the implementation of the activities of the specific Project, the regulatory framework
for the designation of the body responsible for the operation and maintenance of the Project, the existence and operation of a Branch (if applicable) The legal documents that need to be provided, per category of organization (public, public equivalent, private) are the following:

All the necessary documents can be in the native language of the Beneficiary. 
Additionally, the organigramme can be drawn by you, signed and stamped. Through the above documents it is demonstrated that the participating Beneficiary has the competence/ capacity/ experience etc. to participate in an administrative level at the project but also has experience in the thematic area of the project.

Partnership declaration a. Do all organizations have to sign and stamp in one page or each partner can sign in a different page? b. Does the date of signature has to be the same for all partners?

The Partnership declaration in Annex 1 can be signed by each PB on a separate page by hand (in that case stamped also), or by electronic signature.
Attention: Each PB can sign in a separate page, but the file should be only one that will be uploaded on MIS.
The date of the signature may differ per partner.

Please clarify in what language should the offers be presented – is it acceptable for them to be in Bulgarian language? This is recommended taking into account that the applicants can use the public procurement platform for collection of offers which uses only Bulgarian language ( https://app.eop.bg/today?pk_vid=b75fb0ca8c60356b17489433459d6ce6)

Yes, offers can be submitted in the national languages of the applicants. In the case of Bulgarian applicants, it is acceptable to submit offers in Bulgarian, especially considering that they may use the national public procurement platform (https://app.eop.bg)

Regarding the requirements for justification of budget, the JoB Manual envisages that “applicants are required to submit supporting documents justifying the costs selected under budget categories a) staff and b) external expertise, by providing pricelists from possible providers, offers, documentation regarding the average cost of institution salaries (..), etc. Additionally, on pg 3 it is noted that, according to the maturity sheet requirements, Applicants are requested to submit supporting documents in case infrastructure and/ or purchase of equipment foreseen in the budget, i.e. infrastructures budget analysis, pricelists from possible providers, offers, Bill of quantities and costs etc. Please clarify if the applicants should submit all the supporting documents, or only some of them which are necessary under the national legislation and/or relevant to the respective equipment.

In general, applicants are expected to justify the costs under each budget category in a detailed manner, as outlined in the JoB Manual. For the budget categories Staff, Office & Administration, and Travel & Accommodation, applicants may attach supporting documents to further substantiate their proposal—such as those indicative examples listed in Annex 4—though this is not
mandatory.
However, for the budget categories External Expertise & Services, Equipment, and Infrastructure, the submission of supporting documents is required. All documents referred to in Annex 6 (Maturity Sheet) as existing—such as studies, permits and licenses, letters of support, bills of quantities and costs, etc.—must be attached to the Application Form in MIS, if they are available and where required by national legislation.

A state forest enterprise is among selected partners and it possesses licenses for afforestation, since it is part of their activity. Can it implement afforestation by itself, following the internal procedures, and not outsource this activity using public procurement?

If the state forest enterprise is a project partner and afforestation is part of its allocated tasks under the project, it may implement the activities by its own means, using its own resources following the Bulgarian Legal Framework and the necessary decisions imposed by its internal procedures, without public procurement. In this case, those expenditures are to be budgeted in staff cost budget category, but still bear in mind that according to REGULATION (EU) 2021/1059 form 24.06.2021 Staff costs shall be limited to the following: (a) salary payments related to the
activities which the entity would not carry out if the operation concerned was not Undertaken. In that sense, please justify in your application the activities which the entity would not carry out if the operation concerned was not Undertaken.
In cases where the activity requires the purchase of materials or of equipment or external expertise services from third parties, national and EU public procurement rules must be followed accordingly.

Please clarify whether Bulgarian applicants should envisage costs for verifications in their budgets.

In the Greece–Bulgaria Programme 2021–2027, costs for verifications are not applicable for beneficiaries from either country.

Please clarify if the preparation costs will be eligible even if they are not fully paid before the deadline for application in Stage B. The question concerns cases in which beneficiaries put clauses with responsibilities to contractors which go beyond the deadline for application to Stage B – for example, revision of project documents in case of evaluators recommendations, etc. Additionally, the beneficiaries can put clauses of payments which are due after the project is approved, etc.

The provision for the preparation costs is set out in the Programme & Project Implementation Manual.
Preparation cost must be included in the Application Form/Stage B in the Deliverable 1X1 “Preparation Activities” (where X is the number of the beneficiary).
The services or activities must be implemented and there must be at least a commitment decision for them between 1st of January 2021 and the date of submission of the Application Form. The related invoices and payments could be issued and made after the project is approved. The payments for preparation costs should be included preferably in the first request for verification.

About the Preparation Cost, in the implementation manual pages 65 pointed out the sentence ”If the services or activities were implemented and there is at least a commitment decision for them between 1st of January 2021 and the date of submission of the Application Form”. The commitment decision should be prepared under any specific legislation, or its according to the body that will apply for the preparation cost. Also in the pages 65-66 it states that: the following external expertise costs and/ or staff costs for the preparation of the application documents are eligible: c) cost analysis and preparatory research reports for the project activities Programme and Project Implementation Manual d) costs for the preparation of technical design studies, compliance reports, licenses fees, environmental impact assessment studies, technical assessment reports. Can the Project Beneficiary to use the costs for the preparation of the Annex 7:The ‘Project Analysis Report’ and the Annex 8:The ‘Climate Endurance Validation Report’ during the preparation of the project proposal.

Yes, the above costs may be considered as preparation costs, provided that all other applicable eligibility conditions are met.

For an organization with “partially recoverable” VAT status, and considering Law 3281, 17/05/2023/ art. 24, please clarify if the VAT, in the context of the Programme, will be completely eligible for them. In the AF / Partnership section, how should they fill in the VAT condition question?

VAT is eligible expense for all projects with budget under 5.000.000€ for all types of beneficiaries.
In the AF / Partnership section, each beneficiary is required to declare their applicable VAT status, irrespective of whether VAT is considered eligible or not.

For the category “(e) Equipment Costs,” it is stated on page 62 that the cost of purchase, rental, or financial leasing is eligible provided that it is necessary for the implementation of the project and is foreseen in the Application Form. Is it the acquisition cost of the equipment or the depreciation cost, depending on the period of use from the date of acquisition during the implementation until the end of the project? For research institutions, I understand that according to paragraph 3 of Article 256 of Law 4957/2022 (Government Gazette A’ 141/21-07-2022), “…Scientific and other equipment, as well as scientific instruments… are fully depreciated, regardless of their acquisition value, on the date of completion of the project/program under which they were acquired,” this includes the full cost of the equipment that will be purchased and used in the project. I understand that this applies to categories of beneficiaries that fall into the following categories: a) national, regional or local public bodies b) bodies governed by public law (as defined in Article 2(4) of Directive 2014/24/EU) meaning bodies that have all of the following characteristics: 1. they are established for the specific purpose of meeting needs in the general interest, not having an industrial or commercial character; 2. they have legal personality; and 3. they are financed, for the most part, by the State, regional or local authorities, or by other bodies governed by public law; or are subject to management supervision by those authorities or bodies; or have an administrative, managerial or supervisory board, more than half of whose members are appointed by the State, regional or local authorities, or by other bodies governed by public law; However, what applies for the entities (c) to (e),? Is the acquisition cost eligible, or the depreciation costs, according to the methodology they use and depending on the duration of their use in the project? I am referring to the following entities: bodies governed by private law, non-profit organizations founded according to private law can be eligible under the following conditions as a whole: a. they are not established with the goal to obtain profit, b. they do not distribute profits to the shareholders, c. they should have at least completed one accounting year of operation before the launch of the specific call for proposals. This rule is also applicable for the local-regional subsidiary/branch offices. It should be noted that private companies, not falling under the conditions listed at point (c) are not eligible. d) international organisations registered under the national law of the Member States of the Programme can be considered as eligible if they fulfil the criteria foreseen for the non-profit bodies governed by private law. However, international organisations operating under international law are not eligible e) European Grouping of Territorial Cooperation (EGTC). Eligible EGTC must be governed by the law of one of the participating countries where the EGTC has its registered office. EGTCs located outside the Programme area and not registered in one of the Member states participating in the cross-border Programme are not eligible for funding An EGTC cannot be a sole beneficiary of a project proposal.

Only for Greek Beneficiaries/As stated exactly in the Programme and Project Implementation Manual, the cost of purchasing, renting, or financial leasing of equipment is eligible, provided that the equipment is necessary for the implementation of the project and has been procured exclusively within the framework of the project. This applies to all project beneficiaries, regardless of their legal form.

In this case, each project beneficiary follows the appropriate accounting rules and standard accounting practices according to the framework that governs it, listing the equipment and costs in its accounting system.

If the equipment is not used exclusively for the project, then its “depreciation” is applied, in accordance with the institutional framework of each entity.

Finally, in the case where the equipment was not procured under the Action (i.e., no payments supported by invoices have been made), but instead it was preexisting on the premises of the entity, then the depreciation expenses of these fixed assets can be considered eligible if the conditions outlined in Article 22 of the Common Ministerial Decision/ Annex 18 are met:

“Depreciation expenses of fixed assets, for which no payments supported by invoices have been made, can be considered eligible if the following conditions are met:

(a)They are allowed by the programme’s eligibility rules,
(b)The fixed assets are clearly needed to carry out the project,
(c) The expense amount is calculated using the appropriate accounting rules and standard accounting practices of the beneficiary, recorded in the beneficiary’s accounting system, and substantiated by documents with equivalent evidentiary value to invoices for eligible expenses, when these expenses are reimbursed on the basis of actual cost according to the format specified in point (a) of paragraph 1 of Article 53 of Regulation (EU) 2021/1060.
An accounting rule is not appropriate if it is tailored to a specific project or a specific funding source,
(d) The expenses relate exclusively to the life time of the project, and specifically to the time period during which the fixed assets are used for the purposes of the project, (e) No public subsidies have been used for the purchase of the depreciated assets.”

Please clarify the percentage of advance payments for Bulgarian and Greek beneficiaries under the call and the procedure to receive it. The PPIM mentions the advance payment on p 101-102, but its size and percentage is not specified.

All types of Beneficiaries are entitled to receive a pre-financing after signing the Subsidy Contract and the Partnership Agreement.
The Beneficiaries from Greece will receive pre financing from the Public Investment Programme in accordance with the procedure described in Q.3.1/A.3.1

The Bulgaria beneficiaries will receive the 20% national co financing from the state budget after the proposal in which they participate is approved and the relevant contract is signed. Advance payment (80%) of the national co-financing is provided after signature of the contract for the national co-financing between the Bulgarian partner and the Ministry of Regional Development and Public Works and upon a request for advance payment submitted to the Directorate TCM.

What are the provisions regarding the disbursement of the 20% national funding? It is stated that the National Contribution to the expenses will be covered by national funding from the State and/or other contributions (local or own funding). I understand that for public entities (beneficiaries of categories (a) and (b), as I mentioned in the above question (2)), in Greece, the 20% contribution comes from the Public Investment Programme (PIP), while for private entities (categories (c) to (e)) it comes from own resources/funding. As for Bulgaria, this will be determined by their legislation (according to page 100 of the PIM, it appears to be under definition), through their national mechanisms and procedures.

With regard to Greek beneficiaries, the procedure is the same for all types/categories of beneficiaries.
The national co-financing for all Bulgarian partners is ensured from the state budget through the Ministry of Regional Development and Public Works.

The procedure regarding the reimbursement of the Union Contribution and the National contribution is described in detail in Annex 18, article 35 of the Applicant’s Package.

Could you please clarify the funding flow? Is there an advance payment, and if so, what percentage of the total amount does it represent?”

The procedure regarding the reimbursement of the Union Contribution and the National contribution is described in detail in Annex 18, article 35 of the Applicant’s Package.

In summary:
for Greek beneficiaries, each project is registered under a distinct Decision for Co-financed Actions (SAEP) of the relevant Region, depending on the beneficiary’s location, or under the corresponding SAE of the competent Ministry in the case of Central Government bodies.
Prior to the payment of the Project activities, each Greek beneficiary submits a funding allocation request via the Monitoring Information System (MIS) to the Interreg 2021–2027 Managing Authority. The Interreg 2021–2027 Managing Authority assesses the justification of the funding request in collaboration with the competent Joint Secretariat and forwards it through the MIS to the Directorate of Public Investments. The standard Public Investment Program (PIP) procedure then follows for the disbursement of the corresponding funds by the Bank of Greece.

For the Bulgarian beneficiaries, the Union contribution (80%) for their certified expenditures is transferred by the Certifying and Verifying Authority of the Programme, to the bank account of the Lead Partner of the respective project. The Interreg 2021–2027 Managing Authority is notified of these transactions. Each Lead Partner is required to transfer the Union contribution to all Bulgarian project beneficiaries within one month from the date the funds are credited to their account. They must promptly inform the Interreg 2021–2027 Managing Authority and the Certifying and Verifying Authority by submitting copies of the relevant bank transfer documents.
Moreover, the beneficiaries from Bulgaria will receive the 20% national co-financing from the state budget. Beneficiaries shall ensure the needed own contribution (public and/or private), if applicable. Advance payment (80%) of the national co-financing is provided after signature of the contract for the national co-financing between the Bulgarian partner and the Ministry of Regional Development and Public Works and upon a request for advance payment submitted to the Directorate TCM.
The Bulgarian partners can find the needed documents for National co-financing contract and payment request documents at the website of the Ministry of Regional Development and public Works: https://www.mrrb.bg/bg/infrastruktura-i-programi/programi-za-teritorialnosutrudnichestvo-2021-2027/interreg-vi-a-gurciya-bulgariya-2021-2027/dokumenti/
All beneficiaries participating in INTERREG Program projects are obligated to maintain a separate interest-free bank account for project-related transactions.

In reviewing the requirements outlined in the Project Maturity Sheet, we understand that for Bulgarian Beneficiaries, the justification of the project budget must be based on the Beneficiary’s Financial Questionnaire (BfQ) and the “respective indicative prices/offers”. To ensure our compliance and proper alignment with Programme expectations, we kindly request clarification on the following points: – Does the term “respective price” refer specifically to the individual prices provided in indicative offers received directly by the Beneficiary? – Or should it instead be interpreted as the average market price for similar items/services, as determined by market research? Does the Programme provide or recommend any official or indicative price lists, reference thresholds, or sources that Beneficiaries should consult when preparing their budget justifications? Is there a validity period for supporting documents (e.g., indicative offers) submitted as part of the maturity documentation? Should all documents be issued within a specific timeframe prior to submission? Your clear guidance on these points will significantly assist us in ensuring the budget justifications submitted fully align with Programme expectations and evaluation criteria.

Bulgarian candidates are responsible for proper planning and justification of budget in JoB to be attached. The budget of the proposal is the maximum amount which the implementation of the action wil require and must be carefully planned and justified.

As introduced in the Project Maturity Sheet, „In general, all documents (Studies, permits and licenses, Letters of support1, Bill of Quantities and Costs for infrastructure/works and equipment e.t.c.), referred as existing in the Maturity Sheet should be attached to the Application Form in MIS (if required by the national legislation and available).

Depending on the type of the potential beneficiaries and type of procurement, the national legislation requires different documents to justify the proposed costs (market research, offers, market consultations, etc. The candidates should bear in mind that the received offers do not bring any advantages of their authors and this is regulated in the respective legislation.

The call does not put any specific requirements or recommendations any official or indicative price lists, reference thresholds, or sources. When preparing the JoB, each candidate should consider that the budget is realistic, it’s size and costs are in line with the limits set by the call. as follows:

The project budget, size and costs are in line with the limits set by the call:
– Project budget requirements (incl. co-financing rate and EU & National funds) (article 7.3 of the Call);
– Partners budget requirements (incl. EU & National funds) ;
– Requirements on eligibility of expenditure (article 7.9-7.15 of the Call)

Nevertheless, the maturity of a project would be supported and enhanced if the partner has already researched the market in terms of prices and these prices are market prices.

The Programme does not provide or recommend any official or indicative price lists or offers. Each Beneficiary, depending on the type of work, equipment, or services, must provide appropriate justification for the proposed budget. Beneficiaries are also responsible for obtaining relevant and up-to-date indicative offers that demonstrate consistency with current market conditions and project requirements. These offers should be recent, as this helps ensure the budget reflects realistic pricing. It is important to note that the approved project budget will be fixed at the time of approval, and any future cost increases may not be covered by the Programme.

At this stage of budget preparation, you may consider using the average value of the offers received.

Regarding the completion of the Project Maturity Sheet, we seek clarification on a discrepancy noted between the threshold amounts defined in the Programme document and those established by Bulgarian national legislation. Specifically, the Project Maturity sheet requires Bulgarian Beneficiaries to fill in the table “OPERATIONAL/MAINTENANCE BODY” if the planned values exceed the following thresholds: • €50,000 for equipment and external expertise/services • €80,000 for infrastructure However, according to the Bulgarian Public Procurement Law, thresholds for direct assignment are defined in Bulgarian leva (BGN), namely: • 50,000 BGN for equipment and external expertise/services • 80,000 BGN for infrastructure This discrepancy creates uncertainty regarding the applicable threshold levels. In this context, we would greatly appreciate clarification on the following: Should Bulgarian Beneficiaries interpret the thresholds outlined in the Project Maturity Sheet according to the national procurement limits (in BGN) set by the Bulgarian Public Procurement Law, or must they directly apply the EUR thresholds provided in the Project Maturity Sheet, regardless of national legal thresholds in BGN?

You should reflect in Annex 6 the activities as required by it, namely those related to equipment, infrastructure, and external expertise & services exceeding €30,000 + VAT for Greek Beneficiaries, and for Bulgarian Beneficiaries, those exceeding €50,000 (VAT included) for equipment and external expertise & services, or €80,000 (VAT included) for infrastructure.

Please clarify whether the budget should be elaborated taking the average amount of received offers for certain budget line, or should the lowest price be taken for the budget.

At this stage of budget drafting you can take into consideration the average amount of the presented offers.

Please clarify how many offers/pricelists are required for a given budget line, piece of equipment, etc.

At least one offer should be presented justifying the item included in the JoB.

Please clarify what is the scope and requirements of “budget analysis” on p. 1, p 3 of JoBC Manual.

This refers to the justification of the cost under the Infrastructure Works category. Annex 6 provides further clarification:

– For Greek beneficiaries, the infrastructure budget should be based on detailed pre-measurements and cost estimates using official price lists.
– For Bulgarian beneficiaries, the budget should be based on Bills of Quantities (BoQ) and respective indicative prices or offers.

Please clarify what changes can be made to budget at Stage B compared to the budget in the approved Concept notes. It is noted in p 7.3. of the Call that “adjustments to the budget for individual work packages or deliverables are permitted as long as the overall budget remains unchanged”, however at Stage A no work packages have been requested in the template of the Concept Notes. More specifically: a. Can additional budget lines be added to the budget, i.e. for project preparation at stage B? b. Can the proportion and distribution between the different cost categories, if it still meets the Call requirements and ceilings (i.e. investment, services, equipment, etc.), as well as the budget amount of the approved Concept Note? c. Can inflation be taken into account in budget preparation via putting a reserve amount for inflation after analyzing the offers received? d. Can beneficiaries change some budget lines from real costs to flat rate or vice versa between stages A and B?

The total project budget of the proposals to be submitted in Stage B cannot deviate from the one submitted and approved during Stage A—unless otherwise recommended in the notification letters of Stage A. The budget per work package or deliverable may be adjusted, as long as the overall project budget remains unchanged. Please note that the core activities (physical outputs) as described and approved in Stage A cannot be modified.

Regarding the specific questions:
– Additional budget lines such as preparation costs can be added, provided that all relevant eligibility criteria are met.
– Changes in the distribution across cost categories (e.g., services, equipment, investment) are allowed, as long as the changes remain within the ceilings and requirements of the Call and the total approved budget is not exceeded.
– Inflation-related costs cannot be accepted as each expenditure item declared in the JoB must be consistent with the submitted offer(s).
– Each project partner must select a method of cost calculation (flat rate basis or real cost basis) for staff costs, for office & administration costs and for travel & accommodation. Different methods may be chosen per partner.
– SCOs declared in Stage A (Concept Note) may be changed in present Stage B.
– SCOs declared in AF/Stage B shall not be modified either during project’s implementation or upon completion.

Please confirm that changes of projects at Stage B are possible compared to the content of Concept Notes, when they derive from received comments and recommendations included in the evaluation results at Stage A.

Yes, this is correct.

I would like to know if we can make a change of partner at this stage, as with some changes that are being made in Bulgaria, we have been contacted with this question. If we can’t at Stage B’ is there a possibility that it can be done afterwards or is there no such possibility?

In the context of the present 1st Call for Project Proposals – STAGE B, are invited EXCLUSIVELY the Partnership Schemes of the relevant positively assessed proposals as approved to participate in Stage B.
The composition of the partnership, as approved in Stage A, shall be maintained without modifications under penalty of disqualification.
During the Implementation phase, there are in duly justified cases provision for the Modification of the composition of the partnership. For more information, please check the Programme & Project Implementation Manual/Modifications/Modifications approved by the MC

If someone from one unit of an organization creates a new account, will he/she be able to “see” and submit all the proposals made by the organization? Is it possible to modify and submit only one proposal?

The user with “Submit AF” role can see (and submit) all proposals.
The user without “Submit AF” and access to all proposals of the organization can see his proposal at any status and all proposals after their approval by the MA.The user without “Submit AF” and access only to his projects can see only his proposals/projects.

Since there are 4 potential beneficiaries tables in the concept note – can we remove the unnecessary ones if there are only two partners (for example…)? Or do we write N/A in the tables?

You may add or omit tables if necessary in this section of the concept note depending on the number of partners you have in your project proposal.

What kind of supporting documents do we need to present to justify the specific budget lines? At Stage A Concept note and at Stage B Project Proposals?

No supporting documents are required at this stage (Stage A). All needed supporting documents will be submitted in Stage B according to the relevant information which will be given analytically in the relevant Call for Project Proposals.

The proposal is prepared by all beneficiaries and is submitted by the Lead Beneficiary. Should it be signed only by the lead beneficiary?

The project proposal should be signed only by the legal representative of the Lead Beneficiary

Should all beneficiaries be registered in MIS?

For the submission of the Concept Note, only the Lead Beneficiary is necessary to be registered in the MIS.
However, for the submission of the Application Form – at the STAGE B’ of the procedure – all the Beneficiaries should be registered in the MIS. We strongly recommend, all Potential Beneficiaries to be registered in the MIS from the begging of the procedure.

Is there any limitation of words or characters in the Concept Note Document?

As far as the length of the Concept Note is concerned, there is no word or character limit on the length of the Concept Note. Nevertheless, in general, all parts in the Concept Note must be answered concise and comprehensive.

Is there a minimum or maximum requirement for the number of output and result indicators a project must have? Are there expected target numbers for each project?

There are no maximum or minimum requirements for the number of the selected indicators that a project proposal must have.
However, the output and result indicators selected and analyzed by the potential beneficiaries are crucial for the successful assessment of the project proposal and in particular:
During the evaluation of the Stage A – see Concept Note Evaluation Grid, criterion 11, and during the evaluation of the Stage B – see Quality Assessment Phase B2, part A2 criterion (a) & (b)

Is it mandatory the Project proposal to contribute to all Programme Output Indicators for the relevant Specific Objective?

Project applicants are invited to submit their Project application under one of the Specific Objectives of the Programme. The Project objectives and the proposed activities shall be clear and in‐line with the Programme Priorities and both shall have an impact on the Greece-Bulgaria area. Each Project is asked to select those indicators that will fit best to the planned results and outputs of the Project. Therefore, a Project applicant can apply a Project proposal only under one Specific Objective and select only the best suitable indicators (see Programme Output & Result Indicators Guide). In any case, each Project is treated as a whole and shall be evaluated as such.

Are the submitted project proposals evaluated per Priority or per Specific Objective?

The submitted project proposals are evaluated and ranked per Specific Objective. Beneficiaries may submit more than one project proposal at the same Specific Objective. In this case, in which the same organization is participating in more than one project proposal, the proposals are competitive.

Do we have to select only one Specific Objective or can we submit a proposal in more than one?

Project applicants are invited to submit their Project application under one of the Specific Objectives of the Programme. The Project objectives and the proposed activities shall be clear and in‐line with the Programme Priorities and both shall have an impact on the Greece-Bulgaria area. Each Project is asked to select those indicators that will fit best to the particular planned results and outputs of the Project. Therefore, a Project applicant can apply a Project proposal only under one Specific Objective.

In case a Project Proposal is rejected after the evaluation procedure, is there a legal administrative complaint procedure to submit our complaints?

During the Evaluation Procedure an administrative “Complaint Procedure” is foreseen:

• After the completion of the Stage A’ / Concept Note Evaluation
• After the completion of the Stage B’ – Phase B1 & B2 / Administrative & Quality Assessment
• After the completion of Stage B’ – Phase B3 / Eligibility & State Aid check

If we will participate in more than five (5) project proposals, which will be the consequences? Will all the project proposals in which we will participate be rejected?

In case a potential Beneficiary will participate in more than five (5) proposals, not all the Project Proposals will be rejected. The first five (5) Project Proposals submitted via MIS will be assessed, the other will be rejected before the evaluation. If all the proposals are submitted during the same day then the time of submission will be the essential criterion for the acceptance or rejection of the proposal.

Does the limitation for a beneficiary to participate in five (5) project proposals apply on Priority of Specific Objective base?

The limitation of maximum five (5) participations apply at Call level – not at the Priority of Specific Objective level.

What is the limitation for a Beneficiary to participate in project proposals? Does this limitation apply for a specific category of Beneficiary e.g. Lead Beneficiary or Beneficiary?

A potential Beneficiary may participate up to five (5) Project Proposals in total for this Call. The above limit applies to all types of Beneficiaries, Lead Beneficiary or Project Beneficiary.

Which will be the documentation needed in this call for the justification of the land and/or buildings property (in the 2nd phase)?

During the 2nd Stage and taking into consideration the input of the project proposals Concept Notes, further instruction will be provided.

In RSO 4.2 Life-long learning we still have the limitation of 600.000 ?

There is no limitation in the ToR of the 1st Call regarding this issue. It is a recommendation.

Taking into account the recommendation for budget of soft measures up to 600 000 EUR per project, is it possible to submit a completely „soft“ project, containing only soft actions and measures ? If yes, how is it supposed to comply with the minimum project budget of 1 000 000 EUR? This question is highly important for Specific objective: RSO4.2, which in fact contains only soft indicative actions and it is logical that projects under this objective should be soft  projects, and adding investment actions to them will most probably be artificial and will put into question the effective usage of programme funds?

According to the Terms of Reference of the 1st Call for Project Proposals paragraph 7.14 “It is strongly recommended that the total Budget of expenditure in categories 2,4,8 and 10 (soft measures), cannot exceed the amount of 600.000€. Nevertheless, we will accept projects exceeding the amount of 600.000€, if well justified, in these categories. However, RSO 4.2 does envisage actions which would result to the purchase of equipment or even expenditure related to infrastructure according to the Programme Document (page 74). Please don’t declare any “artificial” actions to your project as it will be easily detected by the assessors and will result to the rejection of your proposal. Please read pg.73 of the Operational Programme for more information regarding specific objective 4.2. The aim is to receive project proposals that would leave tangible results and that their sustainability would be ensured after the lifetime of the project.

What is the limit for Staff if it is Real costs? If the staff costs is Flat rate, what is it meant by: “up to 20 % of the direct costs other than the direct staff costs of the operation”. What does “direct staff costs mean”?

No limit is set in the Call for project proposals for real costs budgeted under the budget line “Staff costs”.
However, the budget of each beneficiary and project should be well balanced in terms of budget lines and activities.

If flat rate is used for staff costs, the percentage should be up to 20% and is calculated on the budget lines “external expertise and services”, “equipment” and “infrastructure and works” costs of the beneficiary’s budget.

Direct staff costs are those costs that are directly related to the implementation of the project

The choice of flat rate or real cost has to be applied to the whole partnership or at partner level?

The choice of flat rate or real costs under specific budget lines is declared per beneficiary for each project.

If an organization prefers in one project the flat rate for travel, can it choose a real cost methodology in another project at the same time?

The flat rate for “travel and accommodation” costs applies per project and per beneficiary. The same beneficiary can choose flat rate option for “travel and accommodation costs” in one project and real cost option in another project for the same budget category of costs.

Is it possible to apply all categories of flat rate into one project?

Yes, you may use flat rate in the 3 categories (staff costs, office and administration costs and travel and accommodation costs) into one project.

It is possible to use flat rate to all 3 categories – staff costs, office and administration and travel and accommodation – within one project, per beneficiary and within the relevant category limit set in the Call. In this case, first the calculation of the flat rate for staff costs should be made (up to 20% calculated on the budget lines “external expertise and services”, “equipment” and “infrastructure and works” costs of the beneficiary’s budget) and then the flat rates for “office and administrative costs” and the “travel and accommodation costs” applied on the “staff costs”.

Staff can be calculated as 20% of the direct costs. Which are they? Travel are included in direct costs?

Staff costs calculated on flat rate basis should be up to 20% of the direct costs. These are the budget lines “external expertise and services”, “equipment” and “infrastructure and works” costs of the beneficiary’s budget.
Travel and accommodation budget category is not included in the direct costs.

The advance payment is not part of the published documentation of the call and we highly recommend that it should have been included, so that the candidates are aware of the financial conditions of the projects. During the previous info day it was clarified that the Greek partners will have access to up to 100% advance payment, and the Bulgarian partners – only to 80% of national co-financing, which is appr. only 12% advance payment. Is there any possibility for increase of the percentage of the advance payment also for the Bulgarian partners, since this low rate is restricting and puts beneficiaries into unjustified unequal position, especially when the projects are supposed to be implemented in parallel and introduce joint activities and solutions. This problem is highly important for the non-government organizations, which usually do not have significant own funding and rely on the bridge program financing. Most of the national programs also have significantly higher rates of advance payment, reaching the level of 50%.

The advance payment was not included in the call as it is not part of the Terms of Reference of the Call. However, the relevant information is included in present document (see above Q1.4 & Q1.3). This matter concerns the implementation of the project. The amount of pre-financing is decided and provided by the state budget of each country.

Will de minimis ceiling be applied according to the amended EU Regulation from 13 December 2023 according to which the ceiling for a company was increased to 300 000 EUR? (in force as of 1 January 2024).

Yes the de minimis ceiling will be applied according to the amended EU Regulation.

Which one should be considered as correct? a) 1st-Call-for-common-Projects: Page 8, Paragraph 7.13. Communication’ costs cannot exceed 8% of the total project budget and no more than 100.000€, without limits at beneficiary level. b) Implementation Manual_V1_GR_BG: Page 65, Communication’ costs cannot exceed the 15% of the total project budget, without limits at beneficiary level.

The implementation Manual provides guidance and information for all Calls for Project Proposals. If the Terms of Reference of the Call sets other limitations, then those prevail.

Therefore, the first limits (a) apply to the Project proposals of the present Call.

Can the digitization of a space, such as a museum, be in the cost calculation of the equipment?

It depends on the way this digitization will be implemented. It may belong to external expertise cost or equipment cost or both. Moreover, it could also include staff costs in case of in-house development.

Are Digital platforms, ICT tools and software development, counted as equipment / infrastructure?

The development of platforms ICT tools and software is considered as an external expertise cost. If the IT hardware and software are purchased, then they are considered as equipment. Please refer to the Programme and Project Implementation Manual (v. Project Budget Categories (Budget Lines), p.51) for details and exhaustive lists of items that are considered eligible under each category. The above items cannot be declared under the category “infrastructure”.

Are there any travel, accommodation and daily allowance rates per country that need to be taken into consideration when developing the project budget?

These rates are defined by the national law in each country participating in the Greece – Bulgaria Programme and may vary according to the legal status of each Project partner.

Are there any limitations regarding the distribution of budget among the Work Packages?

Specific budget limits are defined in the Terms of Reference of the 1st Call for Project Proposals and in Programme & Project Implementation Manual/ Section B: Project Development and must be respected by all Project Beneficiaries.

Is it possible to create additional budget lines?

No, Project budgets must be structured according to the following predefined six (6) budget lines:
1) Staff costs
2) Office and administrative expenditure
3) Travel and accommodation costs
4) External expertise and services costs
5) Equipment expenditure
6) Infrastructure and works

At STAGE A, for the Submission of Concept Note on MIS, there is an additional Budget Line ‘Cost based on Concept Note’, which you need to select ONLY ON MIS Application Form. This is required solely for technical reasons at STAGE A and applicants should fill in the total budget of the proposed project in this Budget Line. For more information, please consult MIS Guides.

Does the State Aid legal framework apply for Interreg Projects? If yes, what will be the consequences if a specific activity of a Project Partner will be considered as State Aid?

The ERDF co-financing to beneficiaries may be reduced in case of State aid relevance of project activities, in compliance with relevant rules on State aid (see PPIM p.25-29). In such a case State aid is granted under the de minimis regime or GBER within the project.

Do preparation costs need to be declared in a separate Work Package or in a specific Deliverable? Can invoices for preparation costs be issued after the project is approved?

The provision for the preparation costs are set out in the Programme & Project Implementation Manual. Preparation cost must be included in the Application Form/Stage B in the Deliverable 1X1 “Preparation Activities” (where X is the number of the beneficiary).

The services or activities must be implemented and there must be at least a commitment decision for them between 1st of January 2021 and the date of submission of the Application Form. The related invoices and payments could be issued and made after the project is approved. The payments for preparation costs should be included preferably in the first request for verification.

We represent a small nonprofit organization with limited financial resources. In case of the approval of the project proposal in which we will participate, are we obliged to cover the national co financing from our own budget? If not, who will be responsible to cover the national co financing?

All types of Beneficiaries are entitled to receive the national co financing, during the Project Implementation and after signing the Subsidy Contract and the Partnership Agreement.
The Beneficiaries from Greece will receive the national co financing from the Public Investments Programme.
Beneficiaries from Bulgaria will receive the 20% national co financing from the state budget. Beneficiaries shall ensure the needed own contribution (public and/or private), if applicable. The Bulgarian partners can find the needed documents for National co-financing contract and payment request documents at the website of the Ministry of Regional Development and public Works: HERE

We represent a small nonprofit organization with limited financial resources. In case of the approval of the project proposal in which we will participate, are we entitled to receive a pre financing and up to which amount?

All types of Beneficiaries are entitled to receive a pre financing after signing the Subsidy Contract and the Partnership Agreement. The Beneficiaries from Greece will receive pre financing from the Public Investment Programme.
A pre-financing up to 80 % of the national co-financing will be given to Bulgarian partners after the proposal in which they participate is approved and the relevant contract is signed.

Which is the minimum budget limitation of a single beneficiary to participate in a project proposal?

A Beneficiary may participate in a Project Proposal with the minimum budget of 150.000 €.

Which are the minimum and maximum budget limitations of a proposed project?

A Project Proposal should have a minimum budget of 1.000.000€ and a maximum budget of 2.500.000 €.

The goals of the circular economy also involve utilizing waste for clean energy (e.g., heating from agricultural residues). We don’t see to have an intervention category for these actions. Can such initiatives by municipalities be incorporated into any existing  intervention field?

In general if the relevance of each project proposal fits the aim of the specific objective given at the Programme Document is subject to assessment. We advise you to consult the Programme Document (pg.37-48) to judge if your project proposal is relevant.

Separate project webpage for the interreg project on the official page of the beneficiary, this applies for all beneficiaries or only for the LB?

According to Regulation (EU) 2021/1059: Interreg Regulation/Article 36:
“Each partner of an Interreg operation or each body implementing a financing instrument shall acknowledge support from an Interreg fund, including resources reused for financial instruments in accordance with Article 62 of Regulation (EU) 2021/1060, to the Interreg operation by:

providing on the partner’s official website or social media sites, where such sites exist, a short description of the Interreg operation, proportionate to the level of support provided by an Interreg fund, including its aims and results, and highlighting the financial support from the Interreg fund”.

If the project consortium decides that only the LB (or any other PB) will create this page dedicated to the project on their official website, then the least all other PBs have to do is: add on their official website a banner with the project logo which will be an active link redirecting the user to the page dedicated to the project on the website of the LB (or in general on the website of the PB who was in charge to create the page dedicated to the project on their official website).

Can the PBs create a project website?

Project websites are not eligible under this call and for the programming period 2021-2027 in general. Instead, each project will have a dedicated page on the programme website where all project news, events and deliverables will be uploaded/published. In addition, all Project Beneficiaries should provide on their official website a short description of the project, including its aims and results and highlighting the financial support of the Programme (Regulation (EU) 2021/1059: Interreg Regulation/Article 36).

Is it eligible as a capitalization action to widely implement already co-funded tools demonstrating added value and transfer potential?

Capitalization is welcome. However, there must be no double-financing.

An institution located outside the eligible area can participate under conditions. Can it include deliverables of “equipment” and “infrastructure” in its budget? Or no equipment and no infrastructure can take place outside the eligible area?

Regarding the “infrastructure” please check par. 1 of the ToR and the Programme & Project Implementation Manual page 53 “Infrastructure located outside the Programme area, even if it is directly related to the project either for the development or for implementation, shall not be eligible”.

“Equipment” may be considered as eligible if it will be used in favor of the programme’s area.

What is the preferred number of beneficiaries? Is the participation of local or central governmental bodies compulsory or highly recommended?

The minimum number of participants in a project proposal is (2) – on of each partner country – and the maximum number of participants in a project proposal is five (5). The number and the type of participants within this limits depends of the scope of the project, the activities proposed for financing and the authorization of the participating organizations and will be evaluated during the evaluation procedure.

If a project partner is registered outside of the Programme’s eligible area but has an officially registered branch inside the Programme Area is it considered an eligible partner for this call?

In the Terms of Reference of the 1st Call for Common Project Proposals: Paragraph 5. ELIGIBILITY OF APPLICANTS: Organisations located outside the Programme area but having local/regional subsidiary/branch office established in the Programme area are eligible only for Greek Project partners.

Bulgarian partners must have their legal registration located in the eligible Programme area.

Are there any specific criteria, in order to appoint a Lead Beneficiary?

A Lead Beneficiary will be designated by all partners participating in a project to ensure implementation of the entire project (carry out the tasks laid down in Article 26 of Interreg Regulation) and will sign a Subsidy Contract with the Managing Authority.
The Lead Partner must be located either in Greece-Bulgaria:
• be a legal entity.
• hold a dedicated bank account for the project.
• be legally able to transfer funds to foreign countries.
• have a technical and financial capacity and competency to manage the proposed common project.

Can an NGO with relatively low balance sheets participate in the Greece-Bulgaria Programme as Beneficiary?

Each Project Beneficiary must submit specific documents to prove its eligibility, administrative and financial capacity. The partnership scheme and the administration and financial capacity of the Project Beneficiaries are part of the evaluation procedure at STAGE B.

ONLY FOR GREEK BENEFICIARIES – Can Municipalities, Universities and other bodies conclude Programming Agreements (προγραμματικές συμβάσεις) in Greece-Bulgaria Programme?

The case of assuming responsibility for the implementation of a Project instead of the owner of the project, by another body, is provided for in Article 8, point 3 of the YPASYD of INTERREG Programmes 2021-2027 (Government Gazette 3281/Issue B’/17.05.2023), as follows:
“In the cases of actions for which the responsibility for the implementation of the action is assumed by another entity as beneficiary instead of the project owner on the basis of a programming agreement, in accordance with article 44 of Law 4412/2016, as it applies each time, the eligible costs are paid for the act by the project owner or by the beneficiary, depending on what is specified in the programming contract,…”.
Furthermore, the YPASYD lists in detail (points a to h) the conditions that must be met in order the relevant Programming Agreement and the costs derived from it to be eligible.

In addition, article 44 of Law 4412/2016 states that:
“Article 44. Technical competence of contracting authorities in public works contracts and studies

1. The contracting authorities who judge that they do not have technical competence, or their technical competence is incomplete, may in particular:

a) enter into programming agreement, within the meaning of paragraph 6 of Article 12, for concluding, supervising, and overseeing a public procurement for work or study,
b) conclude contracts for the provision of technical services within the meaning of article 52
and
c) be supported by the EKAA of par. 1a of article 41 in the context of its exercise of ancillary purchasing activities.

2. The contracting authority is responsible to the project owner for the proper performance of its duties and to third parties it is jointly and severally liable with the project owner. If the programming agreement does not specify otherwise,
it represents the project owner in court and out of court against third parties during the exercise of its duties until the end of the contract. The ruling bodies are determined by the programming agreement.”

Therefore, from the above it is clear that the conclusion of Programming Agreements is allowed only in cases in which conditions of Article 44 of Law 4412/2016 are met and exclusively for the services described in paragraph 1a of Article 44.
More specifically, the following should apply cumulatively:
a) documented non-existence or inadequate existence of Technical Competency of a Contracting Authority/ potential Beneficiary,
b) assumption of responsibility by another body, exclusively for the services referred to in Article 44 par.1, i.e. “for concluding, supervising and overseeing a public procurement for work or study”, and not for the
provision of other services.

The potential Beneficiary should document, during the submission of the proposal in Stage B, the need to conclude a Programming Agreement in the context of the above.

In Project Selection Criteria for the evaluation of project proposals for funding are included criteria concerning the ability of the potential Beneficiaries to respond to the implementation of the projects, in which case the above
approach should be taken into account during the process of submitting the proposals that will include Programming Agreements.

Is the 20% rule from the project budget for entities not established in the eligible region still applicable? Such a limitation is not specifically highlighted in the call documents. Can Bulgarian universities (research organisations), state institutions, NGOs, etc., from Sofia, Plovdiv, etc., participate in the partnerships without limitations to their budget as a percentage of the overall project budget?

The rule of 20% from the project budget for entities not established in the eligible area does not apply in the present Call.
Organizations/Bodies that are located outside the Programme area and wish to participate as Beneficiaries should demonstrate that they fall into the eligible beneficiaries set in the Call. All beneficiaries should take into consideration the requirement that ‘in principle, all activities of a project should take place within the Programme area’.

Which is the level of eligibility for universities?

Universities may participate in Greece-Bulgaria Programme at University level.

We are representing a nonprofit organization, oriented to environmental issues. Are we eligible to participate in this Call for Proposals?

The Potential Beneficiaries, before participating in a Project Proposal, should check if they are eligible to participate in the Call. For this they should take into consideration the categories of the eligible partners as described in the Call and the legal form of the Potential Beneficiary (e.g. statute, establishment act, tax registration documents and other legal operating documents). In any case, the Potential Beneficiary holds the full responsibility of the decision to participate in a Project Proposal as the eligibility check is a part of the evaluation procedure and will be performed by the MA / JS. In case of non-eligibility during the evaluation procedure, the Project Proposal will be rejected.

Under which conditions an International Organization may participate in this Call for Proposals?

International Organizations, registered under the national law of the Partner States of the Programme, can be considered as eligible if they fulfil the criteria foreseen for the nonprofit bodies governed by private law. International Organizations operating under international law are not eligible.

Under which conditions an EGTC may be considered as eligible?

An Eligible EGTC must be governed by the law of one of the participating countries where the EGTC has its registered office. EGTC located outside the Programme area and not registered in one of the Partner states participating in the cross-border Programme is not eligible for funding. An EGTC cannot be a sole beneficiary of a project proposal.

Who can be considered as an eligible partner and participate in a project proposal?

The following categories of Beneficiaries may be considered as eligible:
• national, regional or local public bodies
• bodies governed by public law (as defined in Article 2(4) of Directive 2014/24/EU)
• non-profit bodies governed by private law,
• international organizations
• European Grouping of Territorial Cooperation (EGTC).

(For Greek Beneficiaries only) Are spin off companies that are registered in the Greek National Startup Registry considered eligible? If not, can you inform us if there will be an opportunity for such companies to participate in an open call of the Greece-Bulgaria Programme?

Spin off companies are not considered eligible for the 1st Call for Project Proposals. In the future there is a plan to launch a call for small scale funds however, the Terms of Reference are not drafted yet.

Is there a percentage of expenses for actions outside the eligible area? I am interested in participating in exhibitions in Europe and case visits of good practices.

There is no percentage of expenses set in the Call, for actions outside the eligible area. However, these actions should be well justified and approved by the MA.

According to page 54 of the P&PM “Purchase of land (over 10% of total eligible cost) is not eligible”. What is the exact meaning and how this rule applies on the project level?

According to article 64 para 1 (b) of EU Regulation 1060/2021 ARE NOT ELIGIBLE “the purchase of land for an amount exceeding 10 % of the total eligible expenditure for the operation concerned; for derelict sites and for those formerly in industrial use which comprise buildings, that limit shall be increased to 15 %; for financial instruments, those percentages shall apply to the programme contribution paid to the final recipient or, in case of guarantees, to the amount of the underlying loan”
Meaning that the cost for land purchase is eligible if this cost does not exceed the 10% of the eligible TOTAL PROJECT’S COST.

Is VAT an eligible expense?

VAT is eligible expense for all projects with budget under 5.000.000€ for all types of beneficiaries.

What is the difference between ‘Equipment’ and ‘Infrastructure & Works’ budget lines?

The budget line ‘Equipment costs’ refers to expenditure for the financing of equipment purchased, rented or leased by a partner, necessary to achieve objectives of the project.
The budget line ‘Infrastructure & Works costs’ refers to expenditure for the financing of infrastructure and construction works related to investments in infrastructure that do not fall into the scope of other budget lines.

What is project expenses eligibility period?

The expenses eligibility period starts at January 1st, 2021, and after the signature of the Subsidy Contract.
Projects’ activities which have started being implemented before the signing of the Subsidy Contract, and in any case after 1/1/2021, should not have been concluded before the application for funding at the present Call for Project Proposals.
The last date for the expense’s eligibility period is December 31st, 2029.

Are the preparation costs eligible? What is the limitation? Does the limitation apply on Beneficiary or on a Project level? They will be calculated on Real Cost or on Simplified Cost bases?

Costs within the budget lines “staff costs, travel and accommodation costs and external expertise and services”, which have been incurred for the preparation of the project, are eligible for funding if they do not exceed the amount of €30.000 at project level and should be calculated on Real Cost basis.