INTERREG IIIB NORTHERN PERIPHERY PROGRAMME Document retention

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INTERREG IIIB NORTHERN PERIPHERY
PROGRAMMEDocument retention closure audits
Fiona Sarjeant, Regional Contact Point Global
Connections, Highlands and Islands Enterprise
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WHY

• European Commission Closure Audit due 2009 (3
  years after end of programme)
• Northern Periphery Guidance notes says that
  supporting documents must be archived and
  preserved until at least 10 years have passed
  after payment of the grant but see below
• Commission Regulations
• Projects must keep supporting documentation for 3
  years after the final payment to the managing
  authority (which follows the final audit) when
  is this?
• NP Guidance says that projects must keep all
  documents until at least 2012 if not longer
  this is not precise enough
• 2016 may be safer
• How will you and all your partners find this out?

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WHO WILL WANT TO SEE THE DOCUMENTATION?
 

• Lead partner
• JPS / Managing Authority for
• Claims
• Spot Checks
• System Audit
• European Commission Auditors for spot checks,
  final audit and beyond
• Project partners may wish reassurance

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WHAT DO YOU NEED TO KEEP

•  

• All supporting documentation must be kept
• Invoices, bank statements, time sheets etc.
• Originals should be available for audit whether
  held by the lead partner or not
• Each partners originals and e-versions must be
  available too

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HOW TO KEEP IT

• Copies or originals?
• NP Guidance is that electronic documents should
  be certified to be in conformity with the
  original what does this mean?
• Authenticating scanned copies
• NB - Copies are not enough, you must have access
  to the original documentation via all partners

 
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CONSIDER

• Will you be able to trace the documents in the
  future
• Continuity of staff
• Copies will your system still be current in
  2012/2016?
• Third parties/partners does everyone understand
  the importance of this and have a document
  retention policy?
• Do you have storage space for all these documents?

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WHAT CAN HAPPEN IF YOU DO NOT COMPLY?

• Repayment of part or all of the grant
• Lead partner principle but could also be taken
  from partners
• The Commission auditors will extrapolate so ALL
  projects may suffer!

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CONCLUSION

• Document retention is very important!
• Without it you could have to pay back ERDF grant
  years down the line
• Ensure that all your partners are aware of their
  obligations
• Maintain correspondence with ALL partners
  (however small) after the project has ended