Programme Implementation Manual

INTERREG ITALY-CROATIA
PROGRAMME 2021 – 2027
Programme
Implementation Manual
1st Call for Proposals

(Version 1.0 – 17th November 2022)
Table of Contents
1. PROGRAMME BASIC FEATURES .............................................................................................................. 6
1.1. Programme overview ............................................................................................................................................... 6
1.2. Programme area ...................................................................................................................................................... 8
1.3. Programme budget and co-financing ....................................................................................................................... 9
1.4. Programme management structures ...................................................................................................................... 10
1.5. Use of Jems ............................................................................................................................................................ 11
1.6. Types of projects – Standard, Small-scale projects, OSI .......................................................................................... 12
1.7. Programme intervention logic and cooperation criteria ......................................................................................... 13
1.8. Synergies and complementarities with EU policies................................................................................................. 16
1.9. Horizontal and cross-cutting principles .................................................................................................................. 20
1.10. Greening principles ................................................................................................................................................ 22
2. LEGAL FRAMEWORK ............................................................................................................................. 25
2.1. Public procurement rules ....................................................................................................................................... 26
2.2. State Aid ................................................................................................................................................................ 30
2.3. Complaints and litigation ....................................................................................................................................... 37
2.4. GDPR, General Data Protection Regulation ............................................................................................................ 39
2.5. Anti-fraud policies .................................................................................................................................................. 39
3. PROJECT GENERATION AND START ....................................................................................................... 41
3.1. Project’s lifecycle ................................................................................................................................................... 41
3.2. Project generation.................................................................................................................................................. 44
3.3. Conditions clearing and contracting ....................................................................................................................... 53
3.4. Lead Partner principle and project start ................................................................................................................. 54
4. COMMUNICATION ................................................................................................................................ 60
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4.1. Introduction on project and Programme communication ....................................................................................... 60
4.2. Project branding, information and visibility rules ................................................................................................... 62
4.3. Project communication strategy ............................................................................................................................ 68
5. FINANCIAL MANAGEMENT ................................................................................................................... 71
5.1. General eligibility requirements ............................................................................................................................. 71
5.2. Hierarchy of rules regarding the eligibility of expenditures .................................................................................... 72
5.3. Time-wise eligibility of expenditure ....................................................................................................................... 73
5.4. Non-eligible expenditure ........................................................................................................................................ 74
5.5. Simplified Cost Options (SCOs) ............................................................................................................................... 75
5.6. Specific cost category provisions ............................................................................................................................ 78

5.6.1. Staff costs .................................................................................................................................................................. 78
5.6.2. Office and administrative costs ................................................................................................................................. 84
5.6.3. Travel and accommodation costs.............................................................................................................................. 86
5.6.4. External expertise and services costs ....................................................................................................................... 88
5.6.5. Equipment costs ........................................................................................................................................................ 92
5.6.6. Costs for infrastructure and works ............................................................................................................................ 98
5.7. Reimbursement of funds ...................................................................................................................................... 104
5.8. Conversion into Euro ............................................................................................................................................ 105
5.9. Recovery of funds ................................................................................................................................................ 105
6. MONITORING AND REPORTING - COMING SOON ............................................................................... 107
6.1. General overview of monitoring .......................................................................................................................... 107
6.2. General overview of reporting ............................................................................................................................. 107
6.3. Monitoring and reporting at Partner level............................................................................................................ 107
6.4. Monitoring and reporting at Project level ............................................................................................................ 107
6.5. Reporting periods................................................................................................................................................. 107
6.6. Assessment of the reports by JS ........................................................................................................................... 107
6.7. Project mid-term review ...................................................................................................................................... 107
6.8. Performance framework and de-commitment ..................................................................................................... 107
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6.9. Durability and ownership of outputs and equipment ........................................................................................... 107
7. PROJECT MODIFICATIONS AND FLEXIBILITY RULES - COMING SOON .................................................. 107
7.1. General principles (types of project modifications) .............................................................................................. 107
7.2. Minor modifications ............................................................................................................................................. 107
7.3. Major modifications ............................................................................................................................................. 107
8. PROJECT CLOSURE- COMING SOON .................................................................................................... 107
8.1. Final progress report ............................................................................................................................................ 107
8.2. Final quality assessment ...................................................................................................................................... 107
8.3. Last application for reimbursement ..................................................................................................................... 107
8.4. Formal closure process ......................................................................................................................................... 107
8.5. Retention and availability of project related documents ...................................................................................... 107
9. CONTROLS AND AUDITS- COMING SOON ........................................................................................... 107
9.1. National control systems ...................................................................................................................................... 107
9.2. Controls performed by the MA/JS ........................................................................................................................ 108
9.3. Audits by the Audit Authority (AA) and Group of Auditors (GoA) ......................................................................... 108
9.4. Audit trail ............................................................................................................................................................. 108
9.5. Avoidance of double funding ............................................................................................................................... 108
10. WHERE TO FIND ASSISTANCE.......................................................................................................... 109
10.1. Programme Events ............................................................................................................................................... 110
10.2. Information days .................................................................................................................................................. 110
10.3. Meetings .............................................................................................................................................................. 111
10.4. Other events ........................................................................................................................................................ 112
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INTRODUCTION
The Interreg VI A Italy – Croatia Programme provides funding for cross-border cooperation in order to
support regional development and economic, social and territorial cohesion.
This Programme Implementation Manual (PIM) is written for project applicants and partners. It sets out
the key information needed both when applying for funding and while implementing the projects. This
document is divided into sections and annexes, all of them complementary and organised according to
the "project life cycle".
In the table of contents, reader can see all the parts of the complete Programme Implementation Manual.
The elements established in the Programme Manual are binding and constitute the rules of the
Programme. These elements are based on the applicable European regulations and approved by the
Monitoring Committee.
DISCLAIMER
Please be aware that contents of the Programme Implementation Manual (PIM) document may be
updated before projects start following decision by Monitoring Committee (MC). The elements
highlighted in colour (“coming soon”) in the PIM sections are under development and are likely to be
amended according to the progress of the work on Jems (e.g. Sections 6. MONITORING AND
REPORTING; 7. PROJECT MODIFICATIONS AND FLEXIBILITY RULES; 8. PROJECT CLOSURE; 9. CONTROLS
AND AUDITS).
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1. PROGRAMME BASIC FEATURES
1.1. Programme overview
The Interreg Italy- Croatia Programme is funded by the European Regional Development Fund (ERDF)
under the European Territorial Cooperation goal of EU Cohesion Policy 2021-2027.
The Programme area’s greatest potential and core driver of development is represented by the Adriatic
Sea: indeed, the strengths deriving from the maritime dimension are numerous, from the strategic
position and good performance of ports in the area, to the impressive richness of biodiversity and the
strong attractiveness of the region for coastal tourism flows. Thus, it is essential to exploit these
opportunities by focusing the cooperation efforts on blue economy domains, in consistency with the EU
Blue Economy strategy.
The Programme’s vision of “Focusing on innovation and sustainability in the blue economy, capitalising
previous cooperation experiences, creating synergies with EUSAIR” will be attained through the
Programme’s five Priorities and 7 Specific Objectives.1
Moreover, the Programme has identified two cross-cutting issues: digitalisation and circular economy, to
sustain the green and digital transition of Europe in 2021-2027:
 Digitalisation as a crosscutting issue could create added value in relation to most of the challenges
identified for SOs, such as:
o intensifying the smart specialisation governance processes and the innovation capacities
of SMEs;
o increasing the human resources qualifications focusing on skills oriented to the new
market’s needs;
1
The Interreg Programme Italy – Croatia 2021-2027 is available at: https://www.italy-croatia.eu/web/it-hr-interreg-2021-
2027
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o improving the knowledge base for policies concerning climate change, biodiversity, fight
against pollution and the related application tools;
o increasing the intermodality capacities of ports and the overall integration of transport
networks;
o contributing to the integration of touristic strategies and to the offer diversification;
o modernising valorisation policies for cultural heritage.
 Circular economy as a horizontal issue can create added value in relation to challenges identified
for SOs, such as:
o research and technological transfer processes;
o SMEs innovation capacities in competitive domains;
o climate change adaptation strategies;
o sustainability of ports and transport solutions.
Table 1. Programme priorities and specific objectives
Priority SO Specific objective(s)

Developing and enhancing research and innovation capacities
1.1
Sustainable growth in and the uptake of advanced technologies
1
the blue economy Developing skills for smart specialisation, industrial transition
1.2
and entrepreneurship
Promoting climate change adaptation and disaster risk
2.1 prevention, resilience taking into account eco-system based
Green and resilient approaches
2
shared environment Enhancing protection and preservation of nature, biodiversity
2.2 and green infrastructure, including in urban areas, and
reducing all forms of pollution
Developing and enhancing sustainable, climate resilient,
Sustainable maritime
intelligent and intermodal national, regional and local
3 and multimodal 3.1
mobility, including improved access to TEN-T and cross-
transport
border mobility
Culture and tourism for
Enhancing the role of culture and sustainable tourism in
4 sustainable 4.1
economic development, social inclusion and social innovation
development
Integrated governance
5 for stronger 5.1 Other actions to support better cooperation governance
cooperation
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1.2. Programme area
The Programme territory spreads around the Adriatic Sea, which constitutes a joint economic and
environmental resource and a natural link able to foster cooperation. The maritime cross-border area
between Italy and Croatia, representing the Interreg Italy - Croatia Programme area, covers the following
NUTS III regions:
Table 2. Programme area (IT provinces and HR counties)
Italy Teramo, Pescara, Chieti (Abruzzo Region),

Brindisi, Lecce, Foggia, Bari, BarlettaAndria-Trani (Apulia Region),
Ferrara, Ravenna, Forlì-Cesena, Rimini (Emilia-Romagna Region), Pordenone, Udine, Gorizia,
Trieste (Friuli Venezia Giulia Region),
Pesaro e Urbino, Ancona, Macerata, Ascoli Piceno, Fermo (Marche Region), Campobasso (Molise
Region),
Venezia, Padova, Rovigo (Veneto Region)
Croatia Primorsko-goranska,
Ličko-senjska,
Zadarska,
Šibensko-kninska,
Splitsko-dalmatinska,
Istarska,
Dubrovačko - neretvanska (Adriatic Croatia region),
Karlovačka (Pannonian Croatia region).
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Image 1. Programme area
All projects must

demonstrate clearly
that they have an
impact on the
Programme area
1.3. Programme budget and co-financing
The Programme overall budget is 216.232.834,00 EUR (ERDF and national co-financing). Total ERDF
budget is 172.986.266,00 EUR and EU co-financing rate is 80%. ERDF financial appropriations per priority
are presented in table below.
Table 3. Programme budget per priority

PRIORITY ERDF AMOUNT (EUR)
1 Sustainable growth in the blue economy 25.283.781,00
2 Green and resilient shared environment 67.263.871,00
3 Sustainable maritime and multimodal transport 35.910.442,00
4 Culture and tourism for sustainable development 33.284.064,00
5 Integrated governance for stronger cooperation 11.244.108,00
TOTAL 172.986.266,00
The indicative allocations of funds to Calls for Proposals are defined in the respective Call Announcement
and available at the Programme website. The ERDF co-financing rate is 80% for all types of projects,
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beneficiaries and regions. Beneficiaries have to ensure the needed co-financing of their activities. For
Italian project partners co-financing is covered by FdR (“Fondo Di Rotazione”).2
1.4. Programme management structures
The Programme structures consist of different bodies that, in compliance with the EU Structural Funds
Regulations, are in charge of managing, coordinating, supervising and controlling the implementation of
the Programme.
Table 4. Programme management

PROGRAMME BODY ROLE
Monitoring Committee (MC) The MC steers the Programme, verifies its sound implementation and it
approves the projects for funding.
It is composed of representatives of Italy and Croatia.
Managing Authority (MA) The MA is responsible for the management and implementation of the
Programme in accordance with the principle of sound financial
management and in line with the applicable EU regulations.
The MA also carries out the accounting function. The MA submits
applications for payment to the European Commission and pays out ERDF
co-financing to Lead partners (LP).
Audit Authority (AA) and Group of The AA carries out system audits and audits on the projects in order to
Auditors (GoA) provide independent assurance to the EC that the Programme
management and control system functions effectively and that
expenditure submitted to the EC is legal and regular.
The AA is assisted by the GoA, comprising of representatives of bodies
responsible for audits in each Programme Member State – Italy and
Croatia.
Joint Secretariat (JS) The JS is established by the MA and it assists the MA and the MC in
carrying out their respective functions.
The JS also undertakes the day-to-day implementation of the Programme
and provides guidance and support to project applicants and
beneficiaries.
National Authority (NA) In cooperation with the JS, NAs provide information to potential
applicants, advise and assist beneficiaries, communicate Programme
achievements and support Programme management. NAs may also
organise National Committees.
2
Ex Law n. 183/1987 and CIPESS Decree n. 78/2021.
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National Controllers Each Member State has a control system to verify that co-financed
activities and costs are implemented in line with applicable laws as well
as Programme rules and requirements.
Italy: Decentralised control system – individual professionals are
appointed as controllers. Italian public administration can appoint
controllers internally.
Croatia: Centralised control system - controls are performed by Ministry
of Regional Development and EU Funds
Contact details and further information on all Programme bodies are available at the Programme website.
1.5. Use of Jems
The Interreg IT-HR Programme 2021-2027 for implementation and monitoring purposes will use the Joint
Electronic Monitoring System (Jems). Jems is a customized version of the common monitoring system
developed by the Interact Programme3, which is used by a large community of Interreg Programmes.
Jems is an online system conceived to cover the full project and Programme life-cycle in one monitoring
tool that allows to reduce the need for additional paper processes to a minimum. Furthermore, the
concept of “one single entry point” of data is followed, avoiding multiple manual entry of the same data,
through automatic transfer of data to different sections in the system. Users can fill in online forms (e.g.
application, reporting, modification…) and upload/download files.
The link to the Interreg IT-HR Jems is available at the Programme website. It can be accessed via standard
web browsers like Google Chrome, Microsoft Edge or Mozilla Firefox (recent versions). For working in
Jems, it is recommended to use a PC or notebook rather than mobile devices.
Upon registration in Jems, users have access to the system as applicant users. Once a project is approved
and contracted, the lead partner (LP) user will be assigned to the project, and it in turn assigns the partner
users to the project partners (PP). Specific access rights as needed by e.g. Programme bodies, controllers,
external experts or auditors will be given by the system administrator through assignment of the
respective role.
3
For more information on the Interact Jems please visit the page https://jems.interact-eu.net
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A helpdesk for technical support specifically dedicated to functioning of Jems can be reached via email
jems.italy-croatia@regione.veneto.it
For further guidance on the different sections and features Jems technical manual will be made available
at Programme website.
1.6. Types of projects – Standard, Small-scale projects, OSI
Types of projects supported by the Programme are:

A. Standard projects
B. Small-scale projects
C. OSI - Operations of Strategic Importance
Each Call for Proposals will clearly indicate the type of projects that are supported. Calls may include all
types of projects or may be limited to one or two types.
The timetable of the Calls for Proposals is available on Programme website and regularly updated:
https://www.italy-croatia.eu/web/it-hr-interreg-2021-2027/home
Standard projects
Complex cooperation projects typically originating from the acknowledgement of a need or a potential
and consequently testing a potential cross-border solution. They implement actions such as the realisation
of new solutions, the testing of new services, the development of strategies, joint action plans and pilots,
the sharing of expertise, the organisation of joint training actions, and the setting-up of new governance
structures. They should be developed based on an innovative project concept, although the capitalisation
of previous projects and results is also strongly encouraged.
Small-scale projects
New forms of cooperation in the Programme area, resulting from the will of reaching new target groups
and allowing newcomers to contribute to the improvement of the social, economic and territorial
cohesion of the cross-border region. Compared to Standard projects, they are shorter, supporting smaller
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partnerships with limited-scope interventions, mainly implemented by smaller organisations, addressing
specific thematic issues and very concrete needs in the area. These projects shall aim at improving legal
and administrative cross-border collaboration, strengthen the communication channels, and increase the
capacities of institutions and stakeholders (including public authorities), for example through the
implementation of awareness-raising campaigns, implementation of training and educational activities,
school exchanges, youth involvement, competition of ideas, other specific actions aiming at improving
and facilitating the cooperation of the organisations on the other side of the maritime border.
OSI - Operations of Strategic Importance

This new kind of projects can help the achievement of Programme objectives by targeted calls for
proposals devoted to specific domains and, consequently, categories of beneficiaries or strategic
challenges and potentials investigated by EUSAIR flagship initiatives.
These projects provide significant contribution to the achievements of the objectives of the Programme
and are subject to particular monitoring and communication measures.
1.7. Programme intervention logic and cooperation criteria
As anticipated, the Programme strategy is defined in 5 Priorities and 7 specific objectives:
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Image 2: Programme priorities and specific objectives
The Programme intervention logic also defines output and result indicators which measure the products
of funded actions and the expected changes (outcomes) for beneficiaries, respectively.
/!\ POINT OF ATTENTION

Programme intervention logic is available on the Programme website. We strongly encourage project
partners to consult that document when develop the project, but also when they produce and document
the outputs and results.
Link between the PROGRAMME and PROJECT intervention logic
The project intervention logic must reflect the Programme intervention logic and it shall:
● comply with one of the 5 Priorities selected by the Programme;

● pursue one of the Specific Objectives (SOs);
● follow a result-oriented approach;
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● be built on current territorial challenges;
● clearly define the objectives, planned activities, outputs, results and related indicators;
● lead to an envisaged change.

The coherence of the project intervention logic with the targeted specific objective of the Programme
is a precondition for a project to be approved and funded.
Cooperation
Cooperation is the heart of each project. In order to be eligible for funding from Interreg IT-HR
Programme, projects must contribute to the first 2 of the following four cooperation criteria as well as to
the third one and/or the fourth one:4
1. Joint development – i.e. partners have to be involved in an integrated way in developing ideas,
priorities and actions in the project development process.
2. Joint implementation– i.e. project activities must be carried out by partners in a cooperative way
that ensures clear content-based links and be coordinated by the lead partner.
3. Joint financing – i.e. the joint project budget shall be organised in line with activities carried out
by each project partner. The LP is responsible for the administration and reporting towards the
Programme bodies as well as the distribution of the funds to the partners.
4. Joint staffing – i.e. the project should not duplicate functions within the partnership. In particular,
project management functions should be appointed only once at project level.
Capitalisation
Capitalisation can be defined as a building process aimed at consolidating the capital built by Interreg
projects and Programmes, with the objectives of:
● improving the transfer of knowledge;

● obtaining additional outputs, building on existing knowledge and experience;
4
According to the art. 23(4) of Regulation (EU) No 1059/2021
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● promoting the re-use and/or transfer of knowledge and outputs to boost performance and
delivery;
● raising awareness and improving the communication of outputs in specific fields of regional policy.
Thus, the final goal of capitalisation is to make sure that outputs are not only transferred, but also re-
used by other specific actors, in order to lead to a gradual improvement in policies.
1.8. Synergies and complementarities with EU policies
In general, the activities of the project should bring additional value or be supplementary to those already
implemented or planned within other EU instruments and initiatives or national schemes. It also means
that each partnership should carefully consider what is the best funding instrument for their idea. In
several cases the Italy Croatia Programme will not be the most suitable option, but would be better
instead a national, regional or another international funding source.
In order to improve the efficiency of their projects, Beneficiaries should seek complementarities and
synergies with other Interreg Programmes in the area (both cross-border and transnational e.g. IPA
Adriatic-Ionian 2021-2027), regional and national Programmes (co-financed by ERDF, ESF+, EMFAF and
CF), the respective Recovery and Resilience National Plans (NRRP), as well as with macro-regional
strategies relevant for the area (particularly EUSAIR).
Any synergies with other funding Programmes and instruments are also encouraged, including Connecting
Europe Facility, LIFE, EU Civil Protection Mechanism, ERASMUS+ and HORIZON EUROPE. With reference
to the latter, the key strategic orientations and expected impacts identified in the Horizon Europe
Strategic Plan, especially concerning the mission "Restore our Ocean and Waters" should be taken into
account as a constant reference, with the common aim of protecting and restoring ecosystems and
biodiversity, achieve zero pollution and reduce greenhouse gas emissions within the EU’s oceans and
waters.
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Apart from the general recommendations mentioned above, the following table shows synergies and
complementarities encouraged specifically per each of the Specific objectives:
Table 5: Synergies with other Programmes, initiatives, policies

Specific objective Synergy with EUSAIR Other synergies
FLAGSHIP (including complementarities and synergies with national and
regional 2021-2027 Programmes and other Interreg
Programmes operating in the same area)
- Horizon Europe
- Synergies with measures envisaged in respective National
Recovery and Resilience Plans aimed at strengthening research
capacities and promoting technology transfer processes in the
field of Blue Economy
- contribution to the European Research Area (ERA) and the
relative strategic objectives outlined in the Communication “A
new ERA for Research and Innovation”
- European Maritime, Fisheries and Aquaculture Fund
PILLAR 1 - BLUE GROWTH - Interreg Programme IPA Adriatic-Ionian
1.1 Developing
- Fostering quadruple - Interreg Programme “EURO-MED”
and enhancing
helix ties in the fields of - Interreg Programme Alpine space
research and
marine technologies and - Interreg Programme “Central Europe”
innovation
blue bio-technologies for - Interreg Programme “Greece-Italy”
capacities and the
advancing innovation, - Interreg Programme “Croatia – Bosnia and Herzegovina–
uptake of
business development Montenegro”
advanced
and business adaptation - ERDF/CF OP Competitiveness and Cohesion (Croatia)
technologies
in blue bio-economy. - ERDF/CF/Just Transition Fund Integrated Territorial
Programme (Croatia)
- RP Friuli-Venezia Giulia ERDF (Italy)
- RP Veneto ERDF (Italy)
- RP Emilia-Romagna ERDF (Italy)
- RP Marche ERDF (Italy)
- RP Molise ERDF-ESF+ (Italy)
- RP Puglia ERDF ESF+ (Italy)
- RP Abruzzo ERDF (Italy)
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PILLAR 1 - BLUE GROWTH
- Fostering quadruple - Horizon Europe
helix ties in the fields of - ERASMUS+
marine technologies and -synergies with other measures envisaged in respective
blue bio-technologies for National Recovery and Resilience Plans aimed at increasing the
advancing innovation, collaboration practices of SMEs and supporting the
business development reinforcement of skills, in particular in the field of the Blue
and business adaptation Economy
1.2 Developing
in blue bio-economy - European Maritime, Fisheries and Aquaculture Fund
skills for smart
PILLAR 1 - BLUE GROWTH - Interreg Programme IPA Adriatic-Ionian
specialisation,
- Bolstering capacity - Interreg Programme “Italy-Slovenia”
industrial
building and efficient - ERDF/CF OP Competitiveness and Cohesion (Croatia)
transition and
coordination of planning - ERDF/CF/Just Transition Fund Integrated Territorial
entrepreneurship
and local development Programme (Croatia)
activities for improving - RP Friuli-Venezia Giulia ERDF (Italy)
marine and maritime - RP Veneto ERDF (Italy)
governance and blue - RP Emilia-Romagna ERDF (Italy)
growth services (with - RP Molise ERDF-ESF+ (Italy)
specific regard to actions - RP Puglia ERDF ESF+ (Italy)
concerning maritime - RP Abruzzo ERDF (Italy)
professional skills).
PILLAR 3 - - Horizon Europe
ENVIRONMENTAL - the Union Civil Protection Mechanism
QUALITY - Development -other measures envisaged in respective National Recovery and
and implementation of Resilience Plans aimed at improving, in their specific context,
Adriatic-Ionian the knowledge base for climate change monitoring and
Sub/regional Oil spill adaptation and/or the effectiveness of all the phases of the civil
contingency plan (with protection process
specific regard to actions - European Maritime, Fisheries and Aquaculture Fund
2.1 Promoting
concerning oil spill risk) - Interreg Programme IPA Adriatic-Ionian
climate change
PILLAR 3 - - Interreg Programme “EURO-MED”
adaptation and
ENVIRONMENTAL - Interreg Programme “Central Europe”
disaster risk
QUALITY - Protection and - Interreg Programme Alpine space
prevention,
enhancement of natural - Interreg Programme “Greece-Italy”
resilience taking
terrestrial habitats and - Interreg Programme “Croatia - Bosnia and Herzegovina–
into account eco-
ecosystems Montenegro”
system based
PILLAR 3 - - Interreg Programme “IPA South Adriatic”
approaches
ENVIRONMENTAL - Interreg Programme “Italy-Slovenia”
QUALITY - Promotion of - Interreg Programme “Slovenia-Croatia”
sustainable growth of the - ERDF/CF OP Competitiveness and Cohesion (Croatia)
Adriatic-Ionian region by - RP Friuli-Venezia Giulia ERDF (Italy)
implementing ICZM and - RP Veneto ERDF (Italy)
MSP as well as to - RP Emilia-Romagna ERDF (Italy)
contribute CRF on ICZM of - RP Marche ERDF (Italy)
Barcelona convention and - RP Molise ERDF-ESF+ (Italy)
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the appropriate - RP Puglia ERDF ESF+ (Italy)
monitoring and - RP Abruzzo ERDF (Italy)
management of marine
protected area.
PILLAR 3 -
ENVIRONMENTAL
- Horizon Europe
QUALITY - Development
- LIFE Programme
and implementation of
- other measures envisaged in respective National Recovery
Adriatic-Ionian
and Resilience Plans aimed at improving the knowledge base
Sub/regional Oil spill
and the monitoring systems for defining policies of protection
contingency plan
of biodiversity and of fight to pollution, especially related to
PILLAR 3 -
2.2 Enhancing water.
ENVIRONMENTAL
protection and - European Maritime, Fisheries and Aquaculture Fund
QUALITY - Protection and
preservation of - Interreg Programme IPA Adriatic-Ionian
enhancement of natural
nature, - Interreg Programme “EURO-MED”
terrestrial habitats and
biodiversity and - Interreg Programme Alpine space
ecosystems
green - Interreg Programme “Greece-Italy”
PILLAR 3 -
infrastructure, - Interreg Programme “IPA South Adriatic”
ENVIRONMENTAL
including in urban - Interreg Programme “Italy-Slovenia”
QUALITY - Promotion of
areas, and - Interreg Programme “Slovenia-Croatia”
sustainable growth of the
reducing all forms - ERDF/CF OP Competitiveness and Cohesion (Croatia)
Adriatic-Ionian region by
of pollution - RP Friuli-Venezia Giulia ERDF (Italy)
implementing ICZM and
MSP as well as to
- RP Emilia-Romagna ERDF (Italy)
contribute CRF on ICZM of
- RP Marche ERDF (Italy)
Barcelona convention and
- RP Molise ERDF-ESF+ (Italy)
the appropriate
monitoring and
- RP Abruzzo ERDF (Italy)
management of marine
protected area.
3.1 Developing
and enhancing -Connecting Europe Facility (CEF) instrument
sustainable, -other measures envisaged in respective National Recovery and
climate resilient, PILLAR 2 - CONNECTING Resilience Plans aiming at improving ports’ inter-modality
intelligent and THE REGION - The capacities to make them greener, more ICT based and secure
intermodal Adriatic-Ionian Multi- and more integrated with the hinterland’s needs
national, regional Modal Corridors (with - European Maritime, Fisheries and Aquaculture Fund
and local mobility, specific regard to - Interreg Programme IPA Adriatic-Ionian
including green/smart port hubs - Interreg Programme “IPA South Adriatic”
improved access concept) - ERDF/CF OP Competitiveness and Cohesion (Croatia)
to TEN-T and - RP Molise ERDF-ESF+ (Italy)
cross-border - RP Puglia ERDF ESF+ (Italy)
mobility
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- ERASMUS+ Programme
- other measures envisaged in respective National Recovery
and Resilience Plans aiming at improving and modernising the
PILLAR 4 - SUSTAINABLE policies for the valorisation of cultural heritage, delocalising
4.1 Enhancing the TOURISM - AIR Cultural tourist flows and promoting new and innovative integrated
role of culture and Routes offers of coastal tourism.
sustainable PILLAR 4 - SUSTAINABLE - European Maritime, Fisheries and Aquaculture Fund
tourism in TOURISM CulTourAir - Interreg Programme “Greece-Italy”
economic PILLAR 4 - SUSTAINABLE - Interreg Programme “Croatia –Bosnia and Herzegovina–
development, TOURISM - DES_AIR Montenegro”
social inclusion PILLAR 4 - SUSTAINABLE - Interreg Programme “IPA South Adriatic”
and social TOURISM - Green - Interreg Programme “Italy-Slovenia”
innovation Mapping for the Adriatic- - Interreg Programme “Slovenia-Croatia”
Ionian Region - ERDF/CF OP Competitiveness and Cohesion (Croatia)
- RP Friuli-Venezia Giulia ERDF (Italy)
- ERASMUS+ aimed at improving the knowledge base about the
legal and administrative CBC obstacles, enhancing institutional
5.1 Other actions and strategic capacities of public authorities and stakeholders,
to support better and reinforcing the capacities in order to better improve the
cooperation multi-level governance dimension.
governance - European Maritime, Fisheries and Aquaculture Fund
- Interreg Programme “EURO-MED”
- Interreg Programme “Centrale Europe”
1.9. Horizontal and cross-cutting principles
UN Sustainable Development Goals (SDGs)

The UN Sustainable Development Goals are one of the main overarching strategies upon which the
Interreg VI-A Italy-Croatia 2021-2027 rests on. Considering the Programme’s priorities, the contribution
to the following targeted SDGs will be monitored during its implementation:
● Goal 12: Ensure sustainable consumption and production patterns;

● Goal 13: Take urgent action to fight climate change and its impacts;
● Goal 14: Conserve and sustainably use the oceans, seas and marine resources.
20
Horizontal Principles
These principles shell be integrated at the project level: during project planning and project
implementation. The respect of horizontal principles is included in the assessment criteria. The
Programme will comply with the following horizontal principles:5
● respecting fundamental rights and complying with the EU Charter of Fundamental Rights;
● ensuring the promotion of gender equality;
● preventing all kinds of discrimination and taking all appropriate steps to guarantee accessibility for
people with disabilities;
● promoting sustainable development, in line with UN Development Goals, the Paris Agreement and
the “do no significant harm” principle.
Approach to Public Procurement

Public procurement refers to the process by which public authorities, such as government departments
or local authorities, purchase work, goods or services from companies. Beneficiaries will be encouraged
to adopt a strategic use of PP to better reach the Programme objectives, including the use of more quality-
related and innovative criteria and the consideration of environmental and social aspects.
New European Bauhaus Initiative

It aims to transpose the EU Green Deal into tangible and positive experiences built around the concepts
of sustainability, aesthetics and inclusion. In order to contribute to this initiative, the Programme will
foster synergies between PO2 and PO4 and complementarities with funds dedicated to the New European
Bauhaus.6
Young Generations
The Programme will encourage the involvement of young people both in funded projects and in cross-
border events. In this regard, youth has been envisaged as a specific target group in Priority 1, Priority 2,
Priority 4 and ISO1.
5
Set in Article 9 of the CPR and in art.8, 10 and 11 of TFEU
6
For more information please consult: https://new-european-bauhaus.europa.eu/index_en
21
1.10. Greening principles
The Italy-Croatia Programme strives to adopt eco-friendly practices for all its daily activities, especially
concerning events and meetings.7 The information that follows is provided as reference and suggestions
for projects willing to concretely put into practice the principles above.
Project publications and dissemination products

 Publications can be disseminated electronically. Printing of publications should be foreseen only if
strictly necessary and only if following a specific dissemination plan;
 Publications should be printed for external communication purposes (if needed only) on both sides
and on recycled paper. For electronic publications, an “eco-friendly” version (less colors, more
compact text, less pages) should be made available for printing purposes;
 Publications should be printed where they are going to be distributed in order to minimize
transportation distances.
Organization of green and inclusive events

Before the event
 Explore if a phone or a video conference could be organized instead of a meeting;
 Green public procurement procedures shall be applied whenever possible.
Setting up and running the event

 Electronic means (e.g. e-mail, website) should be used rather than printed materials for pre-
meeting and follow-up communications;
 Participants are encouraged to use sustainable ways of travelling: for short trips favour train to
coach/plane and if train is not an option, favour car/coach to plane; Participants are encouraged
to share the drive with other participants.
7
In line with Article 9 of Regulation (EU) No 1060/2021.
22
 Information on the greening efforts made at the event is provided electronically before and after
the meeting whenever possible;
 Participants’ bags/packs should be avoided or produced locally using recycled material, and are
reusable;
 In case participant’s packs cannot be avoided, only strictly necessary material should be included
and copying/printing is available upon request at the location of the event;
 The start and end of the meeting are possibly adjusted to the schedules of public transportation
means;
 The caterer is preferably informed on the exact number of participants and is able to re-evaluate
the quantities needed to avoid waste;
 The use of decorative elements such as flowers, banners etc. is minimized;
 A dedicated area can be provided for participants to return material that can be re-used (such as
badges);
 Accessibility for all participants is taken into consideration and the venue adapted for people with
reduced mobility;
 A system that allows all guests to access the catering service could be put in place: long queues
for food are avoided, enough chairs for people to sit down are available, people with disabilities
or special needs are provided with the necessary facilities.
Food and drinks, catering

The organizers of the event take into account the following:
 Locally grown and produced food and drinks are used and menus reflect the seasonal products of
the region;
 The use of organically produced food and drinks is preferred;
 The use of reusable dishes, cutlery, glassware and linens is preferred;
 If disposable items are essential, it is preferable that they have a high content of recycled or plant
based;
 Material are recyclable and that appropriate recycling systems are in place;
23
 At least one vegetarian option is offered;
 Tap water is used and served in jugs instead of in single-use bottles;
 The surplus of edible food should not be wasted but possibly donated.
Local transport
Clear instructions are provided to participants on appropriate public transport and/or walking
arrangements from point of arrival or departure (railway station, airport) to the venue, accommodation,
town center, etc. This is provided by e-mail shortly before the event and can be additionally displayed at
the venue.
Venue and accommodation
Priority is given to locations available in the premises of one of the project participants in order to reduce
the need for staff to travel. If possible, all waste produced at the venue is sorted for recycling and
sufficient, well-marked bins are provided in both participants and staff areas. It is possible to regulate the
temperature within the building. Use of natural light is preferred and the use of stage lights is kept to the
strict necessary. The hotels are located near public transportation and as close as possible to the
conference facilities (preferably within walking distance or reachable by public transport).
24
2. LEGAL FRAMEWORK
The regulatory framework for the management of Interreg VI A Italy-Croatia Programme is based on the
Regulation (EU, Euratom) 2018/1046 of the European Parliament and of the Council on the financial rules
applicable to the general budget of the Union and repealing Regulation (EU, Euratom) No 966/2012.
Furthermore, all general rules concerning the structural and investment funds are also applicable unless
differently specified. The following legal norms and documents apply (non-exhaustive list):
 Regulation (EU) 2021/1060 laying down common provisions on the European Regional
Development Fund, the European Social Fund Plus, the Cohesion Fund, the Just Transition Fund
and the European Maritime, Fisheries and Aquaculture Fund and financial rules for those and for
the Asylum, Migration and Integration Fund, the Internal Security Fund and the Instrument for
Financial Support for Border Management and Visa Policy (Common Provisions Regulation - CPR);
 Regulation (EU) 2021/1058 on the European Regional Development Fund and on the Cohesion
Fund (ERDF Regulation);
 Regulation (EU) 2021/1059 on specific provisions for the European territorial cooperation goal
(Interreg) supported by the European Regional Development Fund and external financing
instruments (Interreg Regulation);
 Implementing acts and delegated acts adopted in accordance with the aforementioned
regulations;
 Other regulations and directives applicable to the implementation of projects co-funded by the
ERDF;
All above regulations are available in their latest version in the EUR-Lex database of European Union Law:
https://eur-lex.europa.eu/homepage.html.
In case of amendment of the above-mentioned legal norms and documents, the latest version applies.
25
2.1. Public procurement rules
General principles
The acquisition of works, supplies or services from economic operators by means of a public contract is
subject to rules on public procurement which secure transparent and fair conditions for competing on the
common market. Rules differ depending on the kind of goods and/or services to be purchased, as well as
depending on the value of the purchase and the legal status of the awarding institution. They are set at
the following levels:
1. EU rules as set by the applicable directives on the matter;

2. National rules;8
3. Internal rules of the partner organization;
4. Programme rules (see specification below).
A matter of principle, the strictest rules must always be applied.
Each contract should be awarded on the basis of objective criteria that ensure compliance with the
principles of transparency, non-discrimination and equal treatment and which guarantee that tenders are
assessed under the conditions of effective competition.
Here some of the most common errors and weakness experienced in public procurement procedures
project participants are asked to avoid:
 use of the wrong procurement procedure: since the applicable procedure changes according to
the future contract value, when calculating the value of a contract, the maximum total amount
that may be paid during the entire contract period (incl. potential renewal periods) needs to be
estimated;
 imprecise definition of the subject-matter of the contract to be awarded;
 short deadlines for the submission of tenders;
8
National rules include laws on public procurement, related delegated or implementing acts or any other generally
applicable legally binding rules and decisions.
26
 artificially splitting the estimated contract value in order to reach the value range for direct
awards;
 unlawful application of exemption rules;
 direct award procedure for urgent matters caused by insufficient planning by a project partner or
any other circumstances attributable to the project partner;
 direct award for having already satisfactory worked with a certain external provider in the past;
 discriminatory selection criteria;
 restrictive technical specifications.
Failure to comply with the procurement rules set out at EU, national, internal or Programme levels will
have financial consequences. The Programme follows the “Guidelines for determining financial corrections
to be made to expenditure financed by the Union under shared management, for non-compliance with the
rules on public procurement”9 by applying correction rates based on the type and significance of the non-
compliance.
To avoid any loss of funds, and in case of control, project partners must therefore be able to prove that
the award of contracts complies with aforementioned principles and, when applicable, public
procurement rules.
Project partners cannot contract one another in the framework of the same project. This is due to the fact
that the roles of project partner and service provider are different and not compatible. This applies to all
partnership.
Programme rules on procurement

In order to guarantee a harmonized standard in contracting procedures in both Italy and Croatia and to
accomplish sound financial management principle, the Programme requires from beneficiaries to give
evidence of adequate market researches for contracts with a value between EUR 10.000,00 (excl. VAT)
and the threshold set by the applicable EU and national rules.
9
Annex to the Commission Decision C(2019) 3452 final
https://ec.europa.eu/transparency/documents-register/detail?ref=C(2019)3452&lang=en
27
This means that in such cases, unless stricter national rules apply, beneficiaries must perform and
document the execution of adequate market researches (e.g. through collecting bids, using centralized e-
procurement services, price list from Internet etc.). This is meant to provide sound knowledge and
sufficient information on the relevant market allowing for sound comparison of offers in terms of price
and/or quality and a profound assessment of the adequacy of the price.
When doing market research, the Programme strongly encourages beneficiaries to carry out “Bid at three”
procedure (while other models are not excluded).
Even for contracts having a value below EUR 10.000,00 (excl. VAT) or below national threshold (if stricter
than the Programme rule), the adequacy of costs must always be ensured. Upon request, beneficiary must
provide evidence on procurement.
Scope of application of public procurement rules

Different rules apply depending on the legal status of the awarding institution:
 Public authorities and other institutions falling under the scope of application of the procurement
laws10 (including international organizations) must comply with the applicable rules on public
procurement;
 Entities not falling under the scope of application of the public procurement laws (e.g. private
companies, NGOs or other associations of private bodies) are not required to follow public
procurement procedures unless there are national or internal rules, which oblige them to do so.
However these organizations must comply with the basic principles on which the procurement
rules are based and must provide evidence of an adequate market research for estimated contract
values above EUR 10.000,00 (excl. VAT), as described above, and of the result of assessment of
offers and justification of contract award.
10
Namely, “contracting authorities” within the meaning of Directive 2004/18/EC or “contracting entities” within the meaning
of Directive 2004/17/EC as further amended.
28
Selection of the awarding procedure
Beneficiaries must choose the appropriate procedure on the basis of an accurate assessment of the value
of the future contract, keeping in mind that the artificial splitting of contracts for remaining below a
certain threshold violates the law. The estimated value of the contract is the basis for the selection of the
procurement procedure to be conducted and accordingly determines the range of the publicity required
for the respective procurement. The specific thresholds set by the European Commission or national
institutions are indicated in the relevant EC Directives and national Laws.
Since procurement law is a complex matter, project participants are strongly recommended to seek
procurement experts’ advice and/or national public procurement authority early enough before
launching an award procedure.
Alternatives to regular procurement procedures

1. In-house subcontracting: requirements from the latest EU Directive on public procurement11 imply
that:
 The contracting authority exercises over the contracted in-house body a control which is
similar to that which it exercises over its own departments;
 More than 80 % of the activities of the controlled body are carried out for the controlling
contracting authority;
 There is no direct private capital participation in the controlled body.12
When all three of the above conditions for an in-house contracting are given, the in-house body can be
contracted by the beneficiary through a direct award. Costs of the contracted in-house body must always
be charged on a real-costs basis or using simplified Cost Options (SCOs) in the same way as the project
partner. In-house costs, if planned as real costs, should be planned and reported under budget line
11
Directive 2014/24/EU of the European Parliament and of the Council of 26.02.2014, art. 12 which also establishes the
methodology for calculating the percentage of activities referred to in point 2
12
With the exception of non- controlling and non-blocking forms of private capital participation required by national
legislative provisions, in conformity with the Treaties, which do not exert a decisive influence on the controlled body.
29
“External expertise and services”. The above provisions concerning in-house contracting apply also to
international organizations receiving funds within Italy-Croatia Programme projects.
2. Contracts for the cooperation between public bodies provided that the provisions of Directive
2014/24/EU Art. 12 (4) are respected.
2.2. State Aid
Public support granted by Interreg VI A Italy – Croatia Programme must comply with State aid rules.
What is State aid?

According to Article 107 of the Treaty on the Functioning of the European Union, in order to be considered
State Aid, a funded activity must fulfil all the following 5 criteria:
1. The aid is provided by the Member State or through State resources (transfer of public resources,
including EU, National, regional or local public funds): in case of Interreg VI A Italy – Croatia
Programme this criterion always occurs;
2. The aid measure gives an advantage to an undertaking which is carrying out an economic activity
in the context of the project. The term “undertaking” is to be interpreted in accordance with EU
law: the definition set up by the European Court of Justice defines the term "undertaking" in a
wide sense as any entity which exercises an activity of an economic nature and which offers
goods and services on the market, regardless the legal form and the way of financing of this
entity. Thus, not only private companies are subject to State Aid rules but also public authorities
and bodies governed by public law as far as they carry out an economic activity on the market.
The question whether a market exists for certain services may depend on the way those services
are organised in the Member State concerned and may thus vary from one Member State to
another.
30
Non-economic activity:
Non-economic activities are understood as activities that can only be carried out by the state, such
as the provision of public goods for which there is no market (e.g. Public education, army, police…).
This is a fluid term, and interpretation is subject to frequent modification. In this respect, please
also consult §17 and 18 of the EC notice on the notion of State aid , which provides details on the
fact that some activities do not constitute State aid following their classification as part of the
prerogatives of official authority13.
3. The aid gives an economic advantage by participating in the project, which an undertaking would
not have obtained under normal market conditions.
Indirect state aid:

An economic advantage can be transferred to third parties outside the project partnership (so
called indirect State aid): e.g. project partner offers training for free to companies in its regions.
4. The economic advantage is selective favouring certain undertakings or the production of certain
goods. Selectivity of the aid is also satisfied for example if it is granted only to undertakings
belonging to a specific geographical area. In case of INTERREG VI A Italy-Croatia Programme
focusing on a specific cross-border area or specific economic sectors, this criterion potentially
occurs. Consequently, this criterion must be checked considering the real impact of the project
outputs and results at territorial level and in the same way, if the measures are selective as well
as they do not address all the undertakings, but they only focus on some specific sectors.
5. The aid distorts or threatens to distort competition and trade within the European Union: as the
Interreg VI A Italy – Croatia Programme is a ETC Programme this criterion potentially occurs as the
aid measures could be intended not to be local, but cross-border.
If one single criterion is not fulfilled, the assistance granted is not subject to the EU rules on State Aid.
13
Commission Notice on the notion of State aid as referred to in Article 107(1) of the Treaty on the Functioning of the
European Union (2016/C 262/01)
31
It is to be noted that the Interreg VI A Italy – Croatia Programme does not support undertakings in
difficulty, unless authorised under de minimis aid or temporary aid rules established to address
exceptional circumstances.14
Interreg VI A Italy – Croatia Programme and State aid

During the project assessment, the JS, supported by external experts if needed, shall verify State aid
compliance of the submitted applications through a dedicated assessment focused on the five criteria
listed above, with particular attention to the assessment of the status of “undertaking” of the partners
and of the existence of an economic advantage for the undertaking.
The analysis of State aid, may lead to the identification of a high or low risk of State Aid compliance
associated with each project proposal and consequently to the following scenarios:
 the project activities are not State Aid relevant and the Application Form does not foresee the risk
of State Aid compliance: in this case no state aid conditions are set in the Subsidy Contract;
 the project does contain a risk of State Aid compliance which can be removed: in this case,
Interreg VI A Programme might ask the project partners to exclude certain activities from the
project proposal or to take measures in order to eliminate the state aid cause (e.g. wide
dissemination also to competitors of certain project outputs or adapting activities of the project).
Specific obligation will be included in the Subsidy Contract;
 direct State aid granted to one or more partners: in this case the entire budget allocated to the
concerned partner is regarded as State aid granted under the General Block Exemption Regulation
(GBER)15 or, in exceptional cases, under de minimis16 Regulation;
14
Art. 2 point 18 Regulation EU N. 651/2014 (updated version)
15
Regulation EU N. 651/2014 as further amended.
16
Regulation EU N. 1407/2013 as further amended.
32
 indirect state aid granted to third parties outside the project partnership: in this case, a
contractual condition setting a threshold to the aid granted to third parties is set in the Subsidy
Contract.
Direct Aid Granted under GBER

The General Block Exemption Regulation (GBER) allows to implement a wide range of public support
measures without prior notification to the EC, as long as all criteria given in the regulation are fulfilled. It
includes a block exemption for aid granted in the context of Interreg projects (GBER Article 20). As other
Programmes, also Interreg VI A Italy – Croatia Programme will make use of this opportunity to grant direct
State aid. Article 20 GBER allows up to 80% of public funding of costs arising for companies, when taking
part in an Interreg project as partner. The costs mentioned in this article correspond to the cost categories
foreseen by the Programme. The aid granted by the Programme amounts to the whole ERDF budget of
the concerned partner (s), up to a ceiling of 2 million EUR of total public contribution per partner and per
project.
See examples below:

PP TOTAL BUDGET ERDF contribution (80%) Co-financing 20%provided by
granted under art. 20 GBER the PP
EUR 500.000,00 EUR 400.000,00 EUR 100.000,00
EUR 300.000,00 EUR 240.000,00 EUR 60.000,00
It is very important to highlight that partners receiving the ERDF from the Programme under the GBER
regime cannot receive any additional public co-financing to their budgets (e.g. Italian PPs cannot receive
the Italian public co-financing - i.e.“Fondo di Rotazione”).
Article 20 A GBER allows to grant aid to an undertaking per project up to EUR 20.000,00.
33
Direct Aid Granted under De Minimis
For partners receiving public co-financing to their budget, the Programme can also grant ERDF financing
as de minis aid, as set out in Commission Regulation UE 1407/2013. According to this Regulation the total
amount of aid granted per Member State to a single undertaking within the selected project co-funded
by the Interreg VI A Italy-Croatia Programme cannot exceed EUR 200.000,00 (EUR 100.000,00 for
companies in the road transport sector) over a period of three fiscal years.
Please note that “single undertaking” in de minimis Regulation means that if a project partner is part of
a group, the entire group is therefore considered as one single undertaking and the de minimis threshold
applies to the entire group.
The notion of single undertaking includes all enterprises having at least one of the following relationships
with each other:
a) One enterprise has a majority of the shareholders’ or members’ voting rights in another
enterprise;
b) One enterprise has the right to appoint or remove a majority of the members of the administrative,
management or supervisory body of another enterprise;
c) One enterprise has the right to exercise a dominant influence over another enterprise pursuant to
a contract entered into with that enterprise or to a provision in its memorandum or articles of
association;
d) One enterprise, which is a shareholder in or member of another enterprise, controls alone,
pursuant to an agreement with other shareholders in or members of that enterprise, a majority of
shareholders’ or members’ voting rights in that enterprise.
Enterprises having any of the relationships referred to in the above points through one or more other
enterprises shall also be considered to be a single undertaking.
The de minimis aid given by the Programme is granted by the Member State Italy (as the country where
the MA is situated) and its amounts to the whole ERDF budget of the concerned partner, as identified in
the application form. In case the Programme sees State aid relevance at the level of the concerned partner
34
this latter will be asked in the application form to choose if the ERDF funds shall be granted as GBER-aid
or de minimis aid (the Programme strongly recommend GBER as it entail less administrative burden for
the project).
Public aid considered by the Programme for the above mentioned de minimis threshold comprises all aid
granted as de minimis aid only by Italian national, regional or local entities, regardless of whether the
resources are provided from domestic sources or are partly financed by the European Union.
As a consequence, partners carrying out State aid relevant activities in the project might have a reduction
of the ERDF granted by the Programme in order to ensure the respect of the applicable de minimis
threshold. Please note that Italian partners (also Private ones) receiving by the MA the Italian national co-
financing (i.e. Fondo di Rotazione) may result as well in a reduction of total aid granted (ERDF+ Italian
National co-financing) in order to respect the applicable de minimis threshold.
Example 1:
A private company located in Italy has applied for funding in an Interreg Italy – Croatia project. The total
budget of this company in the project is EUR 200.000,00 out of which the ERDF support amounts to
EUR 160.000,00 (80 % ERDF financing).
1.1 The company has received from Italian national, regional or local entities a grant of EUR 50.000,00
under the de minimis rule in the same year in which it applied for funding by the Interreg Italy – Croatia
Programme.
According to the de minimis limitation of up to EUR 200.000,00 of public contribution in three fiscal
years, the ERDF granted by the Interreg Italy – Croatia Programme to this company shall respect such
de minimis threshold. The public contribution that can be granted to this company at the date of signing
the subsidy contract amounts to: de minimis threshold (EUR 200.000,00) – public contribution already
received (EUR 50.000,00) = EUR 150.000,00.
35
Accordingly, the ERDF contribution granted by the Programme amounts to EUR 150.000,00 instead of
EUR 160.000,00.
Total budget of this Company = EUR 150.000,00 (ERDF contribution)+ EUR 50.000,00 co-financing
provided by the company;
1.2 The company did not receive from Italian national, regional or local entities grants in the same year
in which it applied for funding by the Interreg Italy - Croatia Programme and neither in the previous two
ones.
The public contribution that can be granted by the Programme to this company at the date of signing
the subsidy contract amounts to: EUR 160.000,00 (ERDF contribution) + EUR 40.000,00 (Italian public
co-financing - i.e. “Fondo di Rotazione).
Total budget of this Company = EUR 160.000,00 (ERDF contribution) + EUR 40.000,00 (Italian public co-
financing);
Example 2:
A private company located in Croatia has applied for funding in an Interreg Italy – Croatia project. The
total budget of this company in the project is EUR 200.000,00 out of which the ERDF support amounts
to EUR 160.000,00 (80 % ERDF financing).
The company received under de minimis rule a grant of EUR 50.000,00 by Croatian entities but nothing
from Italian national, regional or local entities.
The ERDF granted by the Interreg Italy – Croatia Programme to this company, shall remain EUR
160.000,00 since the ceiling to the accumulation of de minimis aid applies “per Member State”.
Total budget of this Company = EUR 160.000,00 (ERDF contribution) + EUR 40.000,00 co-financing
provided by the company (the Italian national co-financing only applies to Italian companies).
36
Indirect Aid Granted to third parties
Project activities might result in advantages granted to undertakings outside the project partnership that
they would not have received under normal market conditions. This might be the case, for example, of
free of charge services, training, or consultancy to companies, including vouchers (a voucher scheme
might be considered as a state aid relevant intervention and state aid provisions might apply in relation
to the recipients participating in the voucher schemes). In such cases, the aid is granted to third parties
who are the final beneficiaries of the project activities. This aid will be granted under GBER article 20 A 17.
Aid granted under GBER article 20 A to an undertaking as final beneficiary of project activities cannot
exceed EUR 20.000,00. The amount of aid granted to each final beneficiary is to be determined by the
concerned partners prior to the implementation of project activities that are affected by indirect aid, and
it shall be approved by the MA/JS.
2.3. Complaints and litigation
Complaints cover any dispute between potential and selected beneficiaries with regard to the proposed
or selected operation and any disputes with third parties on the implementation of the Programme or of
the funded project.
The complaint procedures set-up by the Programme are differentiated in relation to the matter
concerned:
a) Complaints against decisions of the MC on project selection;

b) Complaints concerning Programme decisions on project implementation;
c) Any other complaints outside the responsibility of the MA/JS.
A) Complaints against decisions of the MC on project selection

Please refer to the Project Selection Procedure of the relevant Call for Proposals.
17
Article 20a of Regulation (EU) No 651/2014, introduced by the amending Regulation (EU) No 2021/1237.
37
B) Complaints during Project Implementation
Complaints on MA/JS implementation of the Subsidy Contract
The LP, on behalf of the partnership, may file complaints against acts, omissions and/or decisions of the
Programme during project implementation that are based on the subsidy contract concluded between
the MA and the LP. The MA, with support of the JS, will examine the complaint on basis of the information
provided by the LP. If the issue cannot be solved between MA and LP, the LP can address the competent
court in Venice considering the rules as laid down in the subsidy contract and the relevant provisions of
the applicable Italian law.
Complaints related to Audit and Control Bodies
Complaints against acts, omissions and/or decisions of control and audit bodies (national controllers,
Programme auditors or any other national or EU institution), have to be submitted to the responsible EU
authority or administrative body at Member State level according to the applicable procedures set up at
national and EU-levels.
C) Any other complaints outside the responsibility of the MA/JS
Any other complaints against other persons or institutions performing activities that might affect activities
of the partnership or the rights of beneficiaries and that are outside the sphere of competence of the
MA/JS have to be directed e.g. to the employing or contracting institution or competent administrative
or criminal offices and shall not be addressed to the MA.
38
2.4. GDPR, General Data Protection Regulation18
The Interreg Italy Croatia 2021 – 2027 Programme bodies, such as the Joint Secretariat and Managing
Authority, Controllers bodies and Audit Authority, all carry out tasks that are defined in EU legislation. The
Programme only process19information that is strictly required and needed for the Programme to function
and reach its goals. Such information must by law be kept until the Programme period has been finally
closed.
If any other personal data is collected during project application or implementation, the Programme
bodies will always make sure that the information will be handled professionally and taking account of
requirements for data protection of personal data in accordance with Regulation (EU) 2016/679 of the
European Parliament and of the Council.
2.5. Anti-fraud policies
The Programme Member States and the MA are committed to protect the EU and public funds entrusted
against fraud and corruption according to its administrative capacity.
The term fraud is commonly used to describe a wide range of misconducts including theft, corruption,
embezzlement, bribery, forgery, misrepresentation, collusion, money laundering and concealment of
material facts. It often involves the use of deception to make a personal gain for oneself, a connected
person or a third party, or a loss for another – intention is the key element that distinguishes fraud from
irregularity, which is an act that does not comply with rules but may be the result of genuine errors
committed by beneficiaries claiming funds.
18
REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of
natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive
95/46/EC (General Data Protection Regulation).
19
Art 4. c. 2 ‘processing’ means any operation or set of operations which is performed on personal data or on sets of personal
data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or
alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or
combination, restriction, erasure or destruction.
39
Fraud does not just have a potential financial impact, but can also cause damage to the reputation of the
Programme bodies.
Corruption is the abuse of power for private gain. Conflict of interests exists where the impartial and
objective exercise of the official functions of a person are compromised for reasons involving family,
emotional life, political or national affinity, economic interest or any other shared interest with e.g. an
applicant for or a recipient of EU funds.
Within the Programme, overall responsibility for managing the risk of fraud and corruption has been
delegated to the Managing Authority who has the responsibility for:
 undertaking a regular review, with the help of a risk assessment team, of the fraud risk;
 establishing an effective anti-fraud policy and fraud response plan;
 ensuring fraud awareness of staff and training;
 ensuring that the Managing Authority refers promptly investigations to competent
investigation bodies when they occur;
The Managing Authority has put in place proportionate anti-fraud measures based on a thorough fraud
risk assessment. The Managing Authority carries out a vigorous and prompt review into all cases of
suspected and actual fraud which have occurred with a view to improve the internal management and
control system where necessary. All cases of suspected fraud will be reported further to the police, to the
European Anti-Fraud Office and to the Ministries and regions participating in the Programme.
The responsibility for an anti-fraud culture lies with all those involved in the EU Programmes and projects.
We therefore encourage all partners, contractors, employees, or the general public to assist in preventing
fraud from taking place, putting into place proportionate measures to detect it and making it transparent.
40
3. PROJECT GENERATION AND START
3.1. Project’s lifecycle
The projects funded by the Programme follow a specific cycle which can be summarised as follows:
Image 3: Project’s lifecycle
CALL FOR
PROPOSALS
APPLICATION
CLOSURE
PROCESS
REIMBURSEMENT OF ASSESSMENT
FUNDS
IMPLEMENTATION
MONITORING CONTRACTING
REPORTING
Call for Proposals

The Programme is implemented through open Calls. Each Call for Proposals will clearly indicate the type
of projects that are supported and rules to apply. When necessary, the Programme may implement
restricted or targeted Calls for proposals clearly addressing specific applicants, priorities or specific
objectives.
41
Application process
The application phase concerns the generation of new projects and their submission to the Programme.
In the application form all essential information about the project must be clearly presented as it is the
basis for the quality assessment and subsequently the project selection by the MC.
Project proposals can only be created and submitted through Jems only. The project proposal can only be
submitted by the user that created the project proposal, who should be the Lead applicant. Project
proposals have to be submitted before the deadline stated in the Call.
Assessment
After the submission of project proposals, the assessment and selection procedures take place and include
the following steps:
1. Administrative compliance and eligibility checks - is aimed at verifying the administrative and
eligibility compliance with the requirements set in the Call for proposals.
2. Quality assessment - is aimed at evaluating the quality of admitted and eligible proposals.
3. State Aid assessment (only for projects recommended for funding).
The MC is in charge of the final decision on selecting the operations and may decide to set some conditions
for funding. The decision of MC will be communicated to applicants with the publication of the ranking
list on Programme website.
Contracting
Once a project has been selected for funding and has fulfilled the conditions laid down by the MC, a
Subsidy Contract between the Programme’s MA and the project’s Lead Partner (LP) is concluded. The
subsidy contract establishes the rights and responsibilities of the Lead Partner and the MA.
Implementation
Implementation period is clearly stipulated in Subsidy contract. Reporting periods are also clearly stated
in SC. Project implementation rules provided by Programme must be carefully observed and
implemented.
42
Monitoring and reporting
The Programme promotes and implements an interactive dialogue and a continuous flow of information
with projects in order to closely follow the progress of project implementation. Reporting activities and
costs is an essential task of project management in which the whole partnership is highly involved. It
allows the Programme to monitor project progress and, in particular, to verify the compliance of project
implementation with the approved application form as well as with the rules governing the EU Structural
Funds and the Interreg IT-HR Programme. Project reporting and monitoring are the basis for the
reimbursement of ERDF co-financing to the project.
Reporting and monitoring take place at partner and project levels. The joint reporting at project level
follows a reporting timeframe stated in Subsidy Contract.
In addition to the project progress report, the Programme uses other sources of information to monitor
progress in implementation on a continuous basis. Among others, the Programme uses:
 the project’s website;
 exchange information with the lead partner and partners (e.g., online meetings or phone
conferences);
 mid-term review meetings.
The mid-term review meeting between the Joint Secretariat and the Lead Partner takes place after at half
way during project activities. It offers an opportunity for the Programme to obtain a more detailed picture
of the project’s performance beyond the information provided in the progress reports.
Reimbursement of funds
The Interreg IT-HR Programme follows the reimbursement model of costs incurred and paid by the
beneficiaries. This means that each beneficiary must fully pre-finance its project expenditure.
Beneficiaries should bear in mind that the absence of advance payments from the Programme, and the
time gap between incurring the expenditure and having it reimbursed, may lead to cash-flow challenges.
As stipulated in the subsidy contract, the disbursement of funds to the LP is subject to the condition that
the EC makes the necessary funds available. Should no funds be available, the LP will be duly notified by
the MA/JS.
43
After receipt of funds from the MA, the LP is obliged to transfer in time and in full the share of ERDF which
corresponds to each PP. No amount shall be deducted or hold by LP.
Closure
Closure is final phase in project lifecycle when ex-post monitoring period starts. Archive of project
documents (related to activities and finance) is set-up in closure phase in order to assure retention of
documents for period of 5 years.
3.2. Project generation
How to set the project objectives
Each project must define its overall objective not only with the aim of tackling current territorial
challenges, but also following the need to be compliant with the Programme specific objective.
Image 4: Programme and project’s objectives
44
Definitions of different level objectives:
● Programme specific objective: what the Programme wants to change for its inhabitants in this
thematic area;
● Project overall objective: defines what the project aims to achieve for the benefit of the involved
regions and its target group(s) and points to the planned project results (and territorial change).
After being set, the project overall objective is then divided into several project specific objectives, each
one strictly linked to a Work Package.
● Project specific objective: defines an immediate goal that a project can realistically achieve within
the project lifetime through its planned activities and related outputs and deliverables. It must
clearly contribute to the overall project objective and should be specific and measurable. At the
end of the project, it should be verifiable whether the specific objective has been reached.

Project specific objectives must be:
● precise and relevant for the Programme;
● ambitious, but feasible within the duration of the project.
How to build a project Work plan
A project Work plan is structured into Work Packages (WP) and activities, while its final aim is to produce
deliverables and outputs to achieve concrete results that reach the set objectives.
45
Image 5: Programme and project’s links
Definitions of Work plan elements:
● Work Package (WP): a group of related project activities necessary to produce project deliverables
and main outputs;
● Activity: a specific task performed for which resources are used; the proposed activities shall have
a logical sequence and be planned for the direct benefit of the area concerned by the authorities
involved in the project. Each Work package is divided into activities, each activity can lead to one
or several deliverables;
● Deliverable: a tangible or intangible object developed as a side-product of the project that
contributes to the achievement of a project output. More than one deliverable can be necessary
to produce one output;
● Output: the actual product resulting from the implementation of project activities. It is captured
by an output indicator and directly contributes to the achievement of project result(s) and project-
specific objectives.
46
● Result: describes the advantage of carrying out the project and characterising the change
compared to the initial situation. Results are derived from the outputs achieved by the project. It
must be coherent with project objectives and contribute to the Programme results.
For each activity, applicants must specify who will benefit from the project outputs:
● Target Group: is a group of stakeholders that is targeted by the project and will benefit from the
project results. They should preferably be actively involved in the project implementation and the
development of its outputs.
Given the typology of actions foreseen and the results expected, the Programme has identified the
following target groups for each SO:
Table 6 : Target groups
SO Jems Target Groups
● Local public authority;

● Regional public authority;
● National public authority;
● Sectoral agency;
● Higher education and research organisations
1.1 ● Education/training centre and school
● Enterprise, except SME
● SME
● Business support organisation;
● Interest groups including NGOs;
● General public.

1.2 ● National public authority;
● Higher education and research organisations
● Education/training centre and school;
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● Enterprise, except SME;
● SME;
● General public.

● Sectoral agency (including Civil protection bodies and emergency services);
2.1 ● Higher education and research organisations;
● SME;
● General public (particularly youth).

● Higher education and research organisations;
2.2
● SME;

3.1 ● Sectoral agency;
● Infrastructure and (public) service provider;
● SME;
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● General public.

4.1 ● SME;
● Education/training centre and school;
● Interest groups including NGOs (including DMOs, tourist boards and local
action groups)

5.1 ● Higher education and research organisations;
● SME;
● Interest groups including NGOs (including local action groups and similar);

During the 2021-2027 programming period, management and communication do not exist as separate
WPs anymore. Only Thematic WPs have been envisaged, thus, communication and management must
be integrated into all thematic WPs, as cross-cutting activities.
49
Contribution to Programme Indicators
The Programme has selected two sets of indicators which aim at measuring the outputs and results
achieved by the projects:
● Output indicator (RCO) measures the specific deliverables of the project;
● Result indicator (RCR) measures the effects of the supported project, with a particular reference
to the direct addressees, population targeted or users.
The Programme has identified the most suitable indicators for each Programme Specific Objective. An
information-sheet containing a description of each indicator is available in the Programme Intervention
Logic document to guide the applicants in the drafting of the Application Form and to better explain what
they are expected to achieve.
Each project is required to contribute to both output and result indicators through the implementation of
the activities that compose its Work plan. The contribution to the Programme indicators and their
alignment with the Programme objectives is taken into account when assessing the quality of projects.
When developing projects, applicants are expected to research and take into account existing outputs
and results developed by previous projects funded by Interreg Italy Croatia as well as other Interreg
Programmes and EU financing instruments. This will help to increase the efficiency of the Programme
co-financing because it ensures that project ideas are innovative and not double-funded. In addition, it
improves the effectiveness and impact of cooperation.
Investment(s)
The investment concept is linked to implementation-oriented activities that lead to the development of
outputs relevant for the project.
An investment could enclose Innovative solutions, such as procedures, instruments or tools (including
physical objects, methods, concepts, or services etc.) and the realization of infrastructural interventions,
50
which are implemented at a small scale and are necessary for the successful implementation of the
project.
The investment must clearly contribute to the project overall and specific objectives: it must have a
demonstration, model or pilot character and show a clear cross-border implementation dimension and
effect that the partnership evaluates together. The investment should be well integrated into the work
plan and show a clear benefit for the target groups addressed. It should ideally pave the way to large-
scale investments, thus increasing the impact of the project. Projects should demonstrate that necessary
authorisations for pilot investments (e.g. building permits) are available or can be obtained in a reasonable
time to avoid hampering the overall project implementation.
In the project budget, according to its contents, the Investment can include items that belong to the cost
categories “External Expertise and Services”, “Equipment” and “Infrastructure and works” for e.g. a new
construction of a building or the adaptation of existing infrastructure.

1. All costs related to meeting standards and obligations related to the nature of the investment (e.g.
feasibility studies, revenue generation, environmental impact assessments, climate protection, building
permits, etc.) must be included in the category of external expertise and service costs, unless they are
part of an infrastructure contract.
2. Productive investments can only be supported for SMEs, with notable exceptions as foreseen in Article
5(2) of the ERDF regulation. Pilot investments have to comply with relevant legislation and
environmental policies, as well as with the durability and ownership requirements. Furthermore,
infrastructure investments with an expected lifespan of at least 5 years have to ensure their climate
proofing. In addition to EC guidance, specific rules may be set out by the country in which the
infrastructure investment will be realised. Projects are also encouraged to integrate the principle of
barrier-free accessibility at all levels, with a special focus on physical investments.
3. The LP/PP that will have investment within the project should demonstrate financial capacity and
mechanisms to cover operation and maintenance costs in view of financial sustainability.
51
4. The assessment of expected impacts of investment on climate change will be implemented by the
Programme together with the building permits but only for investments in infrastructures with a total
cost of 1 million Euro or more.
How to plan the budget
All projects are financed through a system of budget-based grants, by reimbursing the ERDF’s component
of the eligible costs of a project. A project’s total cost is estimated beforehand, based on a detailed
calculation of all costs that are eligible for ERDF funding and necessary for implementation of the project’s
Work plan. Eligible partners shall secure stable and sufficient sources of finance to ensure both the project
implementation and the continuity of the organisation's activities throughout the project’s lifespan.
The budget of the project must be drafted “per partner”, according to each partner’s Work plan. Each
partner must also choose a cost option among the ones foreseen by the Programme, while fully
accomplishing the principles of the adequacy of costs and sound financial management. As set out in the
Financial Regulation 2018/1046, the key principles governing the use of EU funds are:
● The principle of economy: it requires that the resources used by the beneficiary in the pursuit of
its activities shall be made available in due time, in appropriate quantity and quality and at the
best price;
● The principle of efficiency: it concerns the optimal balance between resources employed, the
activities put in place and results achieved;
● The principle of effectiveness: it concerns the attainment of the specific objectives set through
the activities undertaken.
The EU grants should not have the purpose or effect of producing a profit for the beneficiaries (profit is
defined as a surplus of receipts over eligible costs incurred by the beneficiaries).
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3.3. Conditions clearing and contracting
The contracting process starts with the letter of notification of approval or “approval under conditions”
which is delivered to the LP. In pre-contracting phase eventual conditions set by MC must be carefully
observed and fulfilled by LP prior contract signature. This process is performed individually between each
LP and the JS. At this stage, the JS asks for any information and documentation needed to prepare the
Subsidy Contract.
The Subsidy Contract

If the project is selected for funding and fulfil the conditions for approval set by the MC, on the basis of
the LP principle, a Subsidy Contract between the MA and the LP is concluded. The subsidy contract
constitutes the legal framework for the implementation of the project.
The Subsidy Contract confirms the final ERDF commitment to the project, it determines the rights and
responsibilities of the LP and the MA, the conditions for support and all the necessary implementing
arrangements. The final application form is an integral part of the Subsidy Contract.
A model of the Subsidy Contract is available on the website of the Italy-Croatia CBC Programme.
The LP has one month for accepting the subsidy contract offer sent by the MA/JS. To accept it, the LP shall
send back to the MA/JS two original print-outs of the subsidy contract that are dated and signed by the
legal representative of the LP institution. Alternatively, the subsidy contract can also be signed and
returned digitally with a qualified electronic signature that is compliant with the eIDAS Regulation
(Regulation (EU) No. 910/2014). The MA will then send back to the LP a countersigned copy of the subsidy
contract.
Note: Programme strongly recommends to use digital signature whenever possible.
If the LP does not accept the subsidy contract offer within the above-mentioned period, the offer loses
validity unless an extension is granted by the MA.
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The Partnership Agreement
The Partnership Agreement (PA) is a document formalizing the organization of the partnership and
defining the responsibilities of each partner for the implementation of the project in accordance with the
final application form. The PA is concluded between the LP and all the partners involved in the project.
The PA clearly states the so called “LP Principle” for the operational management and coordination of the
project. The PA allows the LP to extend the liabilities of the Subsidy Contract to the level of each partner
and comprises provisions that, inter alia, guarantee the rights and obligations of each PP, the sound
financial management of funds allocated to the project, the arrangements for recovering amounts unduly
paid, etc. A model of Partnership Agreement with minimum compulsory contents is provided by the
Programme and made available to beneficiaries. Additional elements may be included in order to tailor
the agreement to the needs of a partnership. Additional provisions included in the document must in any
case be in line with the Programme objectives and the legal framework mentioned in the subsidy contract
and partnership agreement model.
The agreement must be concluded and signed by the partners as soon as possible and before the signature
of the subsidy contract. No payments can be paid out to the lead partner until the partnership agreement
is signed by all the partners. A copy of the signed agreement must be provided to the MA/JS. The MA and
JS will check the partnership agreement in order to verify that it has been signed and that it meets the
minimum requirements set by the Programme.
3.4. Lead Partner principle and project start
After approval, the project will undergo the initiation stage aiming at ensuring a quick start- up of the
project through the accomplishment of the necessary signed contracts and related documents.
Lead Partner Principle
In compliance with the “LP principle”, each project partnership shall appoint one organisation acting
as LP. The LP takes full financial and legal responsibility for the implementation of the entire project.
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The Lead Partner (LP):20
(a)lay down the arrangements with the other partners in an agreement comprising provisions that,
inter alia, guarantee the sound financial management of the respective Union funds allocated to
the Interreg operation, including the arrangements for recovering amounts unduly paid;
(b)assume responsibility for ensuring implementation of the entire Interreg operation; and
(c)ensure that expenditure presented by all partners has been paid in implementing the Interreg
operation and corresponds to the activities agreed between all the partners, and is in accordance
with the document provided by the managing authority pursuant to Article 22(6).

The partnership is strongly advised to agree on an internal reporting procedure and to set internal
deadlines in the Partnership Agreement to ensure that the documents reach the Joint Secretariat on
time. The lead partner should ensure timely submission of the reports and for that purpose it is
suggested to conduct trainings for the project partners. The partners should also carefully consider and
agree on how the results and outcomes of the project really are jointproperty of all project participants
(LP and PP(s)), and how each project participant grants a simple, non-exclusive right of use of any
produced work to all other project participants.
PROJECT START – tasks:

Tasks associated to project start phase, including project management and coordination:
 Setting up Project Steering Committee:
Each project must set the necessary procedures for decision-making and coordination between the
partners. For this reason, projects are requested to set up a Project Steering Committee, an internal body
of the project, composed of representatives of all project partners.
20
In line with Interreg regulation art.26
55
The tasks of the Project Steering Committee include as a minimum:
o Monitoring and validating the project contents: verifying that the project implementation is in
line with activities and outputs defined in the approved Application Form, and validating the
quality of main project outputs and the progress towards achieving set objectives;
o Monitoring of project finances: monitoring the project budget and project spending;
o Review of the management performance and of the quality of progress reports towards the
Programme bodies;
o Decisions on required project modifications (e.g. content, partnership, budget, duration) to be
requested for approval to the Programme bodies. In this case, it will be necessary to address a
request for partnership change to the Programme Authorities;
o Working groups, task forces and advisory groups may be established to coordinate the day-to-
day running of activities, to fulfil specific tasks, etc.
o Adequate representation of involved partners must be observed in establishing decision-
making and coordination mechanisms.
The setup of the project Steering Committee and the organisation of the first meeting must be ensured
as early as possible. At the beginning of the project, the project also establish the Steering Committee
rules of procedures whilst describing in detail the management structure that guarantee the proper
implementation of the project and mark the launch of project activities.
 Organisation of project management:
o Projects need to establish a clear management concept including a decision-making
structure able to steer and monitor project progress and, in case of unforeseen situations
or risks, to adjust projectimplementation and find adequate mitigation measures;
o Project needs to set up the Project management unit (PMU) consisting of:
 Project Manager: is experienced so as to ensure the thematic coordination of the
project activities and work packages; is able to act as a driving force of the project
and to mobilise the partnership in order to achieve the objectives set in the
application; is experienced in management of EU funded projects; speaks and reads
56
fluently English to ensure communication within the partnership and with the
Programme authorities.
 Financial Manager: is experienced so as to ensure the management of the project
budget, including budget modifications, financial reporting and submission of
payment claims to the Programme. FM must ensure that project partners have
received the Interreg funds and verification of the correct transfer of Interreg funds
to the partners; is responsible to closely and regularly monitor the financial
performance of the project partners; works in close contact with the project
coordinator and the partners in order to enable the efficient overall financial
management of the project; ensures that the project does not contribute to the
Programme de-commitment risk; is familiar with accounting/bookkeeping, as well
as with handling international transactions; is aware of the EU and national
legislation regarding financial management and controls, public procurement and,
where appropriate, State aid.
 Communication Manager: should be able to coordinate the communication flow
and communication content production from all the partners, to collect, process
and elaborate complex concepts and data (also scientific) into visually appealing
message easy to convey via different project communication channels to various
types of users.
o Projects should tackle quality management, in order to ensure consistency and coherence
of the information and content of a deliverable, in tight connection with the activity that it
corresponds to. Specifically, for the outputs: a) how the output contributes to the
Programme actions and/or targets, b) how the output can be used and by whom (target
group), what is the benefit for the target groups and the target area, c) how the
sustainability of the output can be ensured;
o Projects should put in place evaluation plan that is related to deciding how the project will
be monitored and assessed to determine the project’s success and effectiveness. An
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effective evaluation plan should show how the project will be monitored and how its
objectives will be met;
o Projects should put in place a risk management plan to address aspects such as possible
modifications to the project plan, to the achievement of outputs and results, partners
dropping out, delays in delivery, etc.). Following risks may be taken into account when
setting up risk management plan (non exhaustive list):
 Strategic - related to the rationale, quality and timely delivery of the project
objective, result or outputs, including to the work plan implementation and to
procurement – linked to the involvement of external experts or consultants in
project implementation;
 Pilot project, innovation and investment related risks – linked to timely availability
of necessary documents, the development or implementation of innovative
technology or solutions or to the investment delivery stages, ownership or
durability issues in case of infrastructure or productive investments;
 Communication – potentially ineffective project communication strategy with
internal or external effects , poor visibility on the Italy Croatia territory making roll-
out or upscaling of outputs difficult, non-compliance by partners or sub-
contractors with Programme publicity rules;
 Finance – linked to the receipt of match-funding required for the project, accuracy
of budgeting or financial milestone-setting for ERDF subsidy contracts, state aid rule
application, individual partner cash flows, etc.
 Kick-off meeting:
o Purpose: organised within a reasonable deadline after the approval of the SC, in order to
ensure that all partners are ready to start the implementation work and are clear about
what steps to take next
o Scope: a) all partners should be present, b) represents an overview of the project contents
and gives the new staff of the project, who did not take part in the preparatory meetings,
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the opportunity to introduce themselves
o Participation of Programme relevant bodies is to be considered in the light of both strategic
role and decisions to be made.
 Mid-term review meeting:
o The projects have to organise the mid-term review at half way during implementation with
the participation of the JS.
o The review complement information collected through continuous reporting and
monitoring and help to reach a common view on the state of play of project
implementation between the partnership and the MA/JS. The review also allows to assess
the effective capacity of the project to achieve its objectives and targets as defined in the
approved application form, also in light of possible external factors. In project reviews the
LP should ensure a close engagement of all project partners in order to discuss the planning
of upcoming activities as well as to identify any deviations and modifications.
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4. COMMUNICATION
4.1. Introduction on project and Programme communication
Project communication contributes to the Programme approach for the communication and visibility that
in the 2021-2027 period is the integral part of the approved Programme21 . In particular, project
communication has to aim at making the stakeholder in the Programme area aware of the project results
and achievements and has become one of the key elements to ensure durability and transferability of
outputs and results. Interreg Programmes have demonstrated that the achievement of good results may
go far beyond the indicators established in the Programmes and imply impacts which are meaningful for
citizens' life but difficult to measure, such as building trust across borders. The success of project
communication depends on establishing and developing continuous relations with the key target groups
and general public throughout and even beyond the project lifetime. The success of Programme
communication depends on good project results and good cooperation between the project partners and
the Programme Authorities. Therefore, it is necessary that the projects ensure constant and regular
contact with MA/JS. The MA/JS will provide communication trainings, templates and technical tools to
projects as support for project communication. In return, the MA/JS expects the projects to deliver
content for communication activities at the Programme level, e.g. content for the Programme website,
recommendations for interviews to partners, high quality photos with public copyright license,
information about upcoming key events or contributions to events, or online and print publications.
APPLICATION PHASE: COMMUNICATION IN PROJECTS

Targeted communication will help projects to achieve aims and ensure transparency in the use of the EU
funds. Communication activities are an important and integral part of project implementation, and thus
require detailed planning as well as adequate allocation of resources. Communication is a transversal
project task and implies the engagement of all project partners. The quality of project communication
results comes from a committed work of all partners and not only the Lead Partner or the partner
responsible for communication activities. Furthermore, a good internal communication management
21
Interreg Italy-Croatia Programme (chapter 5).
60
within the partnership is a key for the successful external communication of the project. Thus, it is
required that each project partner appoints one person responsible for communication. The Lead Partner
must make sure that at the project level is appointed the project Communication Manager responsible
for planning and coordination of communication measures for the whole project.
/!\ POINT OF ATTENTION:

The Programme strongly suggests that the appointed communication manager is experienced in the
community facilitation, digital tools and channels, content preparation, event organization and has a
good level both of written and spoken English language.
IMPLEMENTATION PHASE: PROJECT COMMUNICATION APPROACH

The Application Form in this Programming period doesn’t foresee a dedicated work package (WP) for
communication. Nevertheless, the communication activities must be foreseen and budgeted.
The budget is ineligible for the following activities:
 creation of a project logo;

 the development, hosting and maintenance of a project website/platform or app for
communication and dissemination of the project activities.
The Programme will provide for each of the approved project the project communication kit (including at
least the logo in different versions, templates for poster and billboard/permanent plaque where relevant)
and the project website (CMS).
All partners need to foresee the necessary human resources internally or externally to develop and deliver
the communication activities, as well as any other costs arising from implementation of the
communication activities (i.e. managing and feeding the project website with relevant content, social
digital channels, internal communication tools, acquisition of the licences for the content production such
as i.e. photos for the website, infographics in pro version, data tools for the website embedding, printing
the material, services for events organization, advertising services acquisition, gadgets etc..). Financial and
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human resources must be allocated to ensure the project participation in external events (other than the
Programme events and seminars/trainings) when justified and useful for the project scope. Each project
should allocate resources for its own communication activities and in order to establish a regular work
relationship with the Programme. The partnership should assign communication responsibilities to a
single Partner, whereas a contact person should be designated to act as liaison with the Programme.
When developing the budget for communication, partners should respect the value for money principle.
This means that all activities proposed need to be in direct link with one of the communication objectives
and the specific target groups. Communication related costs should be reasonable and fully in line with
the objectives and deliverables. Projects are invited not to underestimate the communication costs.
4.2. Project branding, information and visibility rules
All projects need to observe a series of compulsory publicity and communication rules laid down in the
EU Regulations22 and this Programme Implementation Manual.
Specific national rules may apply but these must not, under any circumstances, prevail or appear to be in
contradiction with the provisions indicated in the above mentioned documents.
The project partners are obliged to communicate and to inform the stakeholders and direct/indirect
beneficiaries of the operation financed about the support received from the European Union. EU and
project branding illustrative elements (that will contain the Programme elements) have to be clearly and
visibly displayed “on documents and communication material relating to the implementation of the
Interreg operation attended for the general public and participants” (art. 50 of CPR).
Obligations stand for (non-exhaustive list):
• printed publications: reports, promotional handouts;

• audio-visual: videos, audio podcasts, channels;
• digital or electronic materials (websites, web tools, videos, infographics, etc.);
22
Regulation (EU) 2021/1060 of the European Union and of the Council of 24 June 2021, articles 47 and 50
Regulation (EU) 2021/1059 of the European Parliament and of the Council of 24 June 2021, Article 36
62
• events (e.g. on presentations, agendas, bags and other material/gadgets);
• Stationery and office materials;
• Equipment (computers, photo cameras, TV screens etc.).
EU ILLUSTRATIVE ELEMENTS
Projects financed by the Programme must use the following illustrative elements on all documents and
materials as indicated in EU Regulations:23
• The European Union emblem24

• The statement ‘Funded by the European Union’ or ‘Co-funded by the European Union’ written in
full and placed next to the emblem.
• The term “Interreg” used next to the emblem of the Union Project logo
Interact Programme, in collaboration with the European Commission, designed a logo template for all
Interreg Programmes and projects in strict compliance with the aforementioned EU regulations. The
project logo therefore includes the following elements:
• The European Union emblem;

• The statement “Co-funded by the European Union”;
• The Interreg logo;
• The Programme name (“Italy-Croatia”);
• The project acronym.
In order to ensure that project partners comply with the EU communication and visibility rules, and to
prevent risk of ineligibility of costs, a tailor-made communication package will be delivered to each
approved project containing project logo in JPG and EPS files in different version (transparent, CMYK,
black-white, grey scale, negative etc.). In addition, the Programme will design as well as a brand book
23
Article 47 of the Regulation (EU) 2021/1060 and Article 36 of the Regulation (EU) 2021/1059
24
In accordance with Annex IX of the Regulation (EU) 2021/1060
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explaining the rules of logo use and correct application. All Interreg Italy-Croatia projects must use the
logo provided by the Programme and use it in accordance with the brand book. Beneficiaries are advised
to carefully follow branding rules in order to minimise the risk of ineligible costs related to non-compliance
to Programme branding rules.
However, as with logos above, specific websites can still be introduced by projects as an output of the
communication for specific services and products (label or brand) that are connected to thematic activities
and expected to sustain the activities beyond the project duration that deserve a specific dedicated
platform different than the project web-site. These productions should be properly motivated with
indications on how the sustainability is planned during and after the project end, explaining the reasons
why the activity can’t be implemented by the means of the project website. Eventual proposals shall be
expressly accepted by the JS. Please be aware that i.e. specific branded awareness campaigns and events
web pages, online tools for specific visualisations of data and other types of content may be developed
and have to be displayed on the project websites by the means of links and iframe embedding.
PROJECT ACRONYM
The project is identified on the Monitoring System Jems by the means of an acronym. It is strongly
recommended that this acronym does not exceed 12 characters since an excessively long acronym will
complicate the project logo production. The definition of project acronym should follow a few guidelines:
• Be short and easy to remember;

• The acronyms of previous projects shouldn't be repeated in order to prevent any confusion or
mistakes with past projects;
• Be intuitive, meaning that it must correctly identify the project mission and vision;
• Be easy to pronounce and likely to attract the attention. For this reason, technical information
should be avoided, including Programme specific terminology, reference at Italy-Croatia Programme
(already included in the logo) or to Adriatic Sea for example.
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POSTER
Each partner of an Interreg operation must place a poster of a minimum A3 size or equivalent electronic
display with information about the project including the financial support from the Union and the project
logo at a location clearly visible to the public, such as an entrance area of a building. In order to help
project partners to comply with this obligation, the Programme will provide a Poster template available
for download on the Programme website. All project LPs should collect from all the project partners a
photographic evidence of this poster display and send it together with the first activity report.
BILLBOARDS AND PLAQUES

In the case of an Interreg operation exceeding 100.000,00 euros and involving physical investment or the
purchase of equipment, the display of durable plaques or billboards clearly visible to the public, presenting
the project logo is mandatory for each partner claiming investment/equipment costs. The plaque or
billboard must be placed as soon as the physical implementation of the operation starts, is purchased, or
the equipment installed. The Programme shall provide the template for the aforementioned items.
PROJECT WEBSITE
The Programme provides and hosts a complete ready-to-use website to each approved project (please
see the related chapter). Project websites must be updated on a regular basis and provide a short
description of the project in English including its aim and results and highlighting the financial support
from the Union. Concerning project website, only costs related to staff (for regular content updates)
should be budgeted. In case the project develops a specific web tool, a link to the project website must
be placed in a clearly visible place and the update of the latter must not be overlooked.
PARTNER INSTITUTIONAL WEBSITE

All project partners must publish on their official institutional websites (“where such website exists”) and
social media channels the project logo in a visible place, highlight the financial support from the Union
with a short description of the project proportionate to the level of support, including its aims and results.
A link to the project website in the Italy-Croatia CBC Programme platform should also be added.
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EVENTS
The project logo shall be used on agendas, list of participants, event-related publications, promotional
materials and presentations. During the events, projects are encouraged to place the project poster or a
project banner in a readily visible place (e.g. the front of the meeting room). All projects should foresee
enough budget for the organization of at least two high-level dissemination events (i.e. mid-term event
to showcase the achievements and the project progress in reaching the milestones, while the final event
will be the moment to showcase the overall accomplishments during its life time) able to reach wide public
in terms of the number of audience and in terms of the audience composition (ensuring the involvement
of different types of territorial and European actors). All projects should foresee enough budget for
ensuring the active participation in organizing the joint events with the Programme and with the EU
organizations, as well as for the participation to the Programme seminars/workshops/infodays (at least
for the LPs and the members of the PMU).
In addition, the Operations of Strategic Importance and operations whose total cost exceeds EUR
5.000.000,00 must organize a communication event involving the Commission and the Managing
Authority in a timely manner25.
PUBLICATIONS
All project publications, including brochures, newsletters, studies, articles and others must include the
project logo. When this is not possible, for example, in scientific articles, conference proceedings or other
publications, projects should explicitly mention the “contribution from the EU co-financing and the
Interreg Italy-Croatia Programme”. In addition, projects are strongly recommended to publish in the
appropriate section of the Project website the most essential results (or a summary of them) in the official
language of the Programme – English - in addition to the other languages and in the format and language
easy to understand and to disseminate.
25
Interreg Regulation art.36 (4)
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PROMOTIONAL ITEMS
Promotional items can be a good way to raise awareness about a project and enhance the recognition of
the overall Interreg brand. However, they should be produced only if they meet strategic objectives and
are linked to a promotion strategy. Please take notice of some parameters to take into account when
producing goodies:
• is it relevant for the promotion of my project?

• Is it easy to distribute?
• is it useful, creative and memorable enough?
• is it green? It is strongly recommended to adopt a "green approach" for the promotional
gadgets and think about the environmental perspective (avoid plastic).
Again the golden rule: all promotional gadgets should be branded with the project logo and the reference
to the EU co-financing.
SOCIAL MEDIA
Social media, if properly managed, may be very useful to reach a wide range of target audiences. This
communication medium is however very diverse – channels have different rules, language and approach.
All social media channels need regular feeds which can also be time consuming, as well as the community
raising around the new social channel that has limited life-time. The Programme encourages its projects
to develop an online presence through some of the social media channels whenever this fits with their
communication objectives and is in line with the specificities of their target audiences.
Social media has the advantage of being a two way communication channel, meaning that projects can
also get useful feedback from their target groups. The messages posted should therefore reflect the needs
of the project and the timing of project delivery. Although social media is in theory free of cost, projects
that aim to reach their target groups via these channels should foresee the necessary time and resources
to prepare quality content for their social media channels able to inform, stimulate curiosity of their
stakeholders, engage them in the project activities and teach them about new project developments and
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solutions. Thus the projects are encouraged to analyse and map the stakeholders’ social media presence
in order to choose the most relevant channel.
Please note: It is strongly recommended to produce relevant communication products such as short
video-pills, infographics and other visual contents that can be shared on partner social media as well as
on other digital channels of the project, the Programme and other relevant stakeholders.
4.3. Project communication strategy
The projects funded by Interreg Italy-Croatia Programme contribute to the achievement of the
Programme objectives and horizontal principles by answering their stakeholders’ and target groups’
needs as described in the Programme’s intervention logic. Communication is present in all sections of the
project work plan in the application form (AF) with the following logic:
 Where the communication supports the achievement of a specific objective of the project (i.e.
by informing or engaging with the TAs), then activities are listed in the work packages. In each
work package, applicants choose to include zero, one or more communication objectives.
Every project must have at least one communication objective. Communication objectives aim
at changes in a target audience's behaviour, knowledge or belief.
 Where communication supports the partnership coordination (i.e. for facilitating the
communication flow, reaching a common understanding, knowledge raising etc.), then
activities are described in the project management section.
 If communication supports the transfer of project results to target audiences by the whole
partnership, then activities are described in the project.
The above mentioned elements should be put prepared as a plan in order to facilitate the organisation of
the communication activities. This plan is the communication strategy of the project.
The communication strategy should be drafted at the very beginning of the project implementation and
approved by the project steering committee. The strategy should be drafted as a short document that
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clearly states all the project partners’ tasks in the implementation of communication activities, including
a short description of all communication activities, the timeframe and budget allocation.
The communication strategy should support project management and thus be linked to the specific
objectives of the project. For each objective, one or two communication objectives should be defined,
which are relevant in relation to their target groups. Approaches refer to the different types of interaction
between communication players (all project partners) and the audience. The same approach might be
relevant for several objectives, while one objective could also be reached through the implementation of
several approaches. The concrete implementation of an approach is an activity. The activities are
described in the application form and illustrated by deliverables.
STANDARD PROJECTS AND OSI
Should prepare and implement a project Communication Strategy.
SMALL-SCALE PROJECTS
Having small-size budget and restricted timeline the small-scale projects are requested to define and
deliver the Editorial plan (guiding template is provided by Programme) instead of Communication
Strategy.
Possible communication activities and deliverables

The communication activities will be included into the different work packages, there is no work package
dedicated to communication.
Table 7: Communication activities and deliverables

Type of activity Example of deliverables
Event organization Follow-up report
Training methodology
Satisfaction survey and report
Website and social media analytics
Presentation material
Video production (interviews, podcasts, video clips etc)
Knowledge transfer E-learning course
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Training course material
Video course
Stakeholders and beneficiaries database (in Open Data format)
Information provision Newsletter
Communication campaign
Book
Brochure
Interactive digital infographics (on web/social media)
Networking Agreement
Memorandum of Understanding
Protocol
Thematic community setting up Survey/ questionnaire/ collecting information tool
E-learning course
Training course material
Training report Training methodology
Thematic data collection and production of interactive report
Good practices collection and production of interactive report
Stakeholders and beneficiaries database (in Open Data format)
Management and facilitation of digital tool
Monitoring and evaluation of communication activities

The communication system should be tested periodically to ensure that messages are received and
understood and the receivers are satisfied with the method deployed. The monitoring and evaluation of
communication actions can increase their effectiveness, awareness and knowledge raising.
Common indicators enable to improve the quality of the actions carried out, enhancing the comparability
of data and thus laying the basis for future benchmarking. The Programme may decide to adopt common
indicators for communication activities and ask the projects to provide their contribution.
Monitoring is a continuous and systematic process of data collection and helps to verify the achievement
of intermediate objectives in order to improve communication actions during the project life-cycle. These
activities also allow to increase the transparency of communication actions through a clear and consistent
measurement of their impact and effectiveness.
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5. FINANCIAL MANAGEMENT
5.1. General eligibility requirements
Expenditures have to fulfil all the following general eligibility criteria:
● Expenditures are related to the preparation and implementation of the project as approved by the
Monitoring Committee, are essential for the achievement of the agreed project activities and
would not be incurred if the project is not carried out;
● Expenditures are incurred and paid by the beneficiaries indicated in the AF during the eligibility
period of the project;
● Expenditure must comply with the principle of sound financial management (economy, efficiency
and effectiveness);
● Expenditure must comply with the principle of real costs, with the exception of the costs calculated
as Simplified costs options (SCOs);
● Double-funding is excluded;
● Expenditures are supported by invoices or other documents with probative value directly
attributable to a certain beneficiary (with the exception of the costs calculated as flat rates and
lump sums);
● Expenditures are registered in the beneficiary’s accounts through a separate accounting system or
an adequate accounting code set in place specifically for the project (with the exception of costs
calculated on the basis of flat rates or lump sums);
● Expenditures are not in contradiction with any specific eligibility criterion applicable to the
respective cost category;
● Expenditure is in line with the eligibility rules and, where applicable, relevant procurement rules
have been respected;
● An authorised Controller has validated the expenditure (applying risk-based management

verifications).
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5.2. Hierarchy of rules regarding the eligibility of expenditures
The hierarchy of rules applicable to Interreg Italy-Croatia projects in relation to the eligibility of
expenditures is the following:
 European level - EU regulations

 Programme level - specific rules decided for IT-HR Programme
 National/regional level rules applicable in each Member State
 Partner institutional level - internal rules applicable to each partner organisation
Image 6: Hierarchy of eligibility rules
EU
IT-HR
National/
Regional
Partner
This means that partners should first consider EU regulations when incurring expenditure. Where EU rules
do not stipulate provisions, Programme rules apply. If neither the EU nor the Programme has a set rule,
then national/regional legislation applies. Finally, the partner’s internal rules should be followed, if
specific issues have not been covered by previous levels.
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5.3. Time-wise eligibility of expenditure
Expenditure is eligible if it has been incurred by the beneficiary and paid between the 1st of January 2021
and the 31st of December 2029.
Expenditure shall incur in the eligible period in line with the phases of preparation, implementation and
closure of the project:
Image 7: Eligibility of expenditure in time
Preparation Implementation Closure
Up to Starting and From the

the project ending date of ending date of
approval the project as the project to
defined in the the submission
SC of last PR
Lump-sum Lump-sum
Project preparation
The Project preparation phase comprises all activities related to the elaboration and submission of the
Application Form and it ends with the approval of the project including the contracting phase. Preparation
costs are reimbursed through a lump sum.
Project implementation
Costs for the implementation of an approved project are eligible from its start date until its end date as
stipulated in the Subsidy contract (SC).
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Project closure
Closure costs of a project refer to activities related to the preparation and submission of the last progress
report including the control of expenditure of the last reporting period.
The cost of closure activities are reimbursed through a lump sum.
In addition to the closure lump-sum, partners are entitled to report during the closure process the
following costs:
● Project implementation costs (other than staff costs): for expenditures incurred for the last project
period activities (activities that are concluded within project end date and regularly reported in
the project final report), invoices shall be issued and paid within 60 days after the project end date
at the latest;
● Project implementation staff costs (including social charges) which are incurred before the end
date of the project and paid no later than 60 days after the project end date;
● Control costs related to the certification of the last progress report expenditures, where applicable
(in case of external controllers of Italian partners).
5.4. Non-eligible expenditure
The following costs are not eligible (not exhaustive list):
● Interest on debts;
● Purchase of land for an amount exceeding 10% of the total eligible expenditure for the project
concerned. For derelict sites and for those formerly in industrial use which comprise buildings,
that limit shall be increased to 15%;
● Fines, financial penalties and expenditure on legal disputes and litigation;
● Costs of gifts;
● Costs related to fluctuation of foreign exchange rate;
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● In-kind contributions (including unpaid voluntary work);
● Splitting cost items among project partners (i.e. sharing of common costs);
● Discounts not considered when claiming the costs (only the discounted amount is to be regarded
as eligible);
● Fees between beneficiaries of a same project for services, equipment, infrastructure and works
carried out within the project.
Furthermore, the Programme will not support activities excluded from the ERDF scope26 such as the
decommissioning or the construction of nuclear power stations.

In case of projects having a total cost below EUR 5.000.000 (including VAT), VAT is eligible.
5.5. Simplified Cost Options (SCOs)
The Programme makes extensive use of Simplified Cost Options (SCOs) and encourages beneficiaries to
apply this option as much as possible in the view of reducing administrative burden and possible source
of errors. SCOs can take the form of Lump sum, flat rates or unit costs and imply approximations of costs
that can, by definition, overcompensate or undercompensate the costs incurred by the supported
operation. The aim is to shift the focus more on outputs rather than on inputs of the project, in particular
from the management verifications’ point of view and to introduce a significant simplification. In
particular, by applying SCOs project partners should take into consideration that:
● They do not need to provide justification of expenditure and to document that the expenditure has
been incurred, or that the lump sum, or flat rates correspond to reality;
26 See article 7 of Regulation (EU) 2021/1058 – ERDF.
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● Flat rates are calculated on real cost expenditure (budgeted in the application form or reported in the
progress report) in Jems;
● Corrections of reported real cost expenditure will result in a corresponding correction of the flat rate;
● The focus of controls is on the correct reporting of real costs and on verifying that no expenditure
related to the flat rates or lump sum is included in any other budget line.
The list of SCOs available to beneficiaries is as follows:
✔ Lump Sum for Preparation costs (17.000,00€ ERDF + co-financing per Standard project or
2.300,00€ ERDF + co-financing per Small-scale project);
✔ Lump Sum for Closure costs (2.000,00 € ERDF + co-financing per partner of a Standard or Small-
scale project);
✔ 20% Flat for Staff costs (Flat rate of 20% of eligible direct costs other than staff costs);
✔ 15% Flat for Office and administration costs (Flat rate of 15% of eligible direct staff costs);
✔ 15% Flat for Travel and accommodation costs (Flat rate of 15% of eligible direct staff costs);
✔ 40% Flat for all costs excluding Staff (Flat rate of 40% of eligible direct staff costs).
Table 8: Lump sums overview
Lump-sum Type of Project Amount (€) Notes

Preparation costs Standard projects 17.000,00€ (ERDF + co-financing) per project
Small-scale projects 2.300,00€ (ERDF + co-financing) per project
Closure costs Standard or Small-scale 2.000,00€ (ERDF + co-financing) per partner

projects
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Specifications concerning SCOs and in particular Lump sums for Operation of Strategic Importance (OSI)
will be available at a later stage.
The table below provides an overview of applicable combinations of different SCOs by each project.
Table 9: overview of SCOs

Cost categories Option n.1 Option n.2 Option n.3
Staff costs REAL costs (Part time 20% Flat on other REAL costs (Part time with fixed
with fixed percentage direct costs percentage method or Full-time)
method or Full-time)
Office and administrative 40% Flat on Staff costs 15% Flat on Staff 15% Flat on Staff costs
costs costs
Travel and 15% Flat on Staff 15% Flat on Staff costs
accommodation costs costs
External expertise and REAL costs REAL costs
services costs
Equipment costs* REAL costs REAL costs
Infrastructure and works* REAL costs REAL costs
* This cost category is available only for Standard projects.

Flat 20% Staff should not include as direct costs (other than Staff) public contracts exceeding the following
thresholds27:
a) EUR 5.186.000,00 for public works contracts;
b) EUR 134.000,00 for public supply and service contracts awarded by central government authorities
and design contests organised by such authorities;
c) EUR 207.000,00 for public supply and service contracts awarded by sub-central contracting
authorities and design contests organised by such authorities;
d) EUR 750.000,00 for public service contracts for social and other specific services.
27 See article 4 of Directive 2014/24/EU.
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5.6. Specific cost category provisions
The Programme applies six different cost categories in line with the Interreg regulatory framework:
1. Staff costs
2. Office and administrative costs
3. Travel and accommodation costs
4. External expertise and services costs
5. Equipment costs
6. Costs for infrastructure and works
5.6.1. Staff costs

Staff costs consist of gross employment costs of staff employed by the beneficiary implementing the
project. Staff can either be already employed by the beneficiary or contracted specifically for the project.
Staff costs may be reimbursed in one of the following form:
1. as Real costs where the beneficiary must document that expenditure has been incurred and paid
out (proven by the employment document and payslips);
2. as a Flat rate equal to 20% of direct costs other than staff costs (external expertise and services,
equipment, infrastructure and works) with no need to document that the expenditure has been
incurred and paid out.
Each beneficiary must choose one of the above reimbursement options already in the project preparation
phase when drafting the Application form. The same reimbursement option will apply to all staff members
of the beneficiary working in this project and it will be set for the entire project duration. During project
implementation, it is not possible to change the chosen option.
REAL COST
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Option n.1 and n.3 Staff costs reimbursed on a real basis:
Staff costs consist of gross employment costs of staff employed by the beneficiary implementing the
project in one of the following ways:
1a) full time;
1b) part-time with a fixed percentage of time worked per month;
Staff costs shall be limited to the following:
(i) salary payments related to the activities which the entity would not carry out if the operation concerned
was not undertaken, provided for in an employment document, either in the form of an employment or
work contract or an appointment decision, or by law, and relating to responsibilities specified in the job
description of the staff member concerned;
(ii) any other costs directly linked to salary payments incurred and paid by the employer, such as
employment taxes and social security including pensions as covered by Regulation (EC) No 883/2004 of
the European Parliament and of the Council, on condition that they are:
● provided for in an employment document or by law;
● in accordance with the legislation referred to in the employment document and with standard
practices in the country or the organisation where the individual staff member is actually working,
or both; and
● not recoverable by the employer.
Payments to natural persons working for the beneficiary under a contract other than an employment or
work contract may be assimilated to salary payments and such a contract shall be considered an
employment document.
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Overtime is eligible, provided it is in line with the national legislation and the employment policy of the
partner organisation, and it is actually paid to the staff member (it can be foreseen for full-time
employees on the project).
Benefits linked to salary payments are eligible if they are in line with the employment policy of the
partner organisation (e.g., lunch vouchers, bonus payments).
Holidays resulting from the employer's normal obligations are eligible (they form part of the gross
employment cost).
Overheads and any other office and administrative costs, daily allowances and any other travel and
accommodation costs cannot be included under this cost category.
Unpaid voluntary work (i.e. contribution in kind) is not eligible.
Costs of staff are eligible if no other EU funds have contributed towards financing of the same
expenditure item (i.e.: no double financing is permissible according to Article 63(9) CPR).
The following types of working/employment contracts are eligible under this cost category:28
A) Italy
● Permanent staff (“Personale a tempo indeterminato”);

● Temporary staff (“Personale a tempo determinato”);
● Collaborators, term-contract workers;
● Scholarships, PhD Scholarship, Research allowances/grants.
The above-mentioned list may be subject to updates and revisions upon adoption of specifications at
National level.
B) Croatia
28
NOTE: This information should be revised once the NATIONAL RULES for verification are established.
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● Work/Employment Contract (both permanent and temporary) signed both by the legal
representative of the employer and the employee;
● Appointment decision, including temporary appointments (for civil servants) issued by the
legal representative of the employer’s institution which complies with the national
legislation.
Other types of working/employment contracts such as “employees hired by a temporary work agency”
(Lavoro da Agenzia interinale), in Italy, and/or Service/fee based contract (“Ugovor o djelu”), in Croatia,
are not eligible under Staff cost category and may be eligible under External expertise and services.
1a - Calculation of costs for staff working full-time in the project:
For individuals employed by the beneficiary to work full-time on the project, the total gross employment
costs incurred by the employer are eligible.
The fact that the individual works full-time on the project has to be clearly stated in the employment
document itself or, if not mentioned, in a specific assignment document issued for the project.
1b - Calculation of costs for staff working part-time in the project with a fixed percentage of time worked
per month:
For individuals employed by the beneficiary and assigned to work part of their time on the project, eligible
costs shall be calculated as a fixed percentage of working time spent by an employee on the project per
month.
This percentage is set out in the employment document or, if not mentioned already there, in a specific
assignment document issued for the project which is reflecting the employee’s related functions,
responsibilities and tasks to be performed in the project and shall be individually fixed for each employee.
The fixed percentage of the gross employment cost is eligible. The percentage has to be established at
the beginning of the project and should in principle remain the same for the whole project
implementation. However, in case of changes of tasks/responsibilities/functions of the employee, this
percentage can be revised and the employer will have to change the assignment document accordingly in
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order to reflect the incurred changes. It is strongly advised to keep fixed percentage unchanged within
the same reporting period to allow smooth implementation and audit trail.
The reimbursement of staff costs shall be calculated by applying the percentage indicated in the
employment document (/in the assignment document) to the monthly gross employment cost.
EXAMPLE 1a - Staff working full time on EXAMPLE 1b - Staff working on a fixed %

the project on the project
Total monthly salary costs (gross salary Total monthly salary costs (gross salary
and employer´s social charges) = and employer´s social charges) =
€3.000,00 €3.000,00
Percentage of time worked monthly on Fixed percentage of time worked monthly
the project = 100% on the project = 60%
Eligible costs = €3.000,00 * 100% = Eligible costs = €3.000,00 * 60% = €1.800
€3.000,00
Supporting documents for the audit trail:
● Employment document setting out the % of time worked on the project (Full-time or fixed
percentage) and job description;
● Assignment document (only in case that the % of time spent on the project and job description is
not already clearly indicated in the employment document);
● Payslips, and
● Other documents of equivalent probative value which allow proof of payment of gross
employment costs (e.g. an extract from a reliable accounting system of the beneficiary,
confirmation of tax authority, bank statement).
It is expected that basic information on the project such as project name, acronym, partner name and
name of the employee are included in the employment document (or in the assignment document).
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Option n.1 and n.3 (1a or 1b) does not require establishing a separate working time registration system
(i.e.: timesheets are not requested).
20% FLAT
Option n.2 - Staff costs reimbursed as a 20% Flat of direct costs other than direct staff costs
The beneficiary may opt to get the reimbursement of staff costs as 20% Flat of the beneficiary’s direct
costs incurred in a financial reporting period, staff excluded. All eligible costs incurred by the beneficiary
and validated by the national controller under the following cost categories are to be regarded as direct
costs for the purpose of calculating the flat rate:
 External expertise and services costs;
 Equipment expenditure;*
 Costs for infrastructure and works*.
*Not applicable for Small-scale projects.
Given that Office and administrative costs and travel and accommodation costs under Option n.2 will be
reimbursed as flat rates of staff costs they do not form the basis for the calculation of the 20% flat (due
to the need to avoid circular reference).
Direct costs that form the basis for the staff costs calculation must be incurred and paid by the partner
institution as real costs and must not include any indirect costs. If direct costs used as calculation basis for
determining staff costs are found to be ineligible, the determined costs for staff must be re-calculated and
reduced accordingly.
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EXAMPLE 2 – 20% Flat of direct costs other than staff
Validated direct costs in the Reporting period:

30.000,00€ under External expertise and
services
+ 10.000,00€ under Equipment
+ 20.000,00€ under Infrastructure & works
= 60.000,00€ of tot direct costs other than staff
60.000,00€ * 20% = 12.000,00€ of Staff costs to be
reported in the reporting period.
● Only a Self-declaration certifying that employee(s) of the beneficiary institution has/have worked
in the project. Self-declaration is provided only at the beginning (1st reporting period). Please note
that self-declaration may be requested by programme bodies also in later stages of
implementation.
Option n.2 does not require to document that the expenditure for staff costs has been incurred and paid
or to determine the applicable rate. Therefore no documentation on staff costs needs to be provided to
the controller. The documentation of real costs will be requested for other cost categories used as a basis
for the flat rate calculation.
5.6.2. Office and administrative costs

The Programme reimburses office and administrative costs through a flat rate of 15% of eligible direct
staff costs or as part of the 40% flat on eligible direct staff costs.
15% FLAT
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Costs under this category include operating and administrative expenses of the day-to day operations
incurred by the beneficiary and necessary for the implementation of the project and shall be limited the
following elements (exhaustive list):
(a) office rent;

(b) insurance and taxes related to the buildings where the staff is located and to the equipment of the
office (such as fire or theft insurance);
(c) utilities (such as electricity, heating, water);
(d) office supplies;
(e) accounting;
(f) archives;
(g) maintenance, cleaning and repairs;
(h) security;
(i) IT systems;
(j) communication (such as telephone, fax, internet, postal services, business cards);
(k) bank charges for opening and administering the account or accounts where the implementation of an
operation requires a separate account to be opened; and
(l) charges for transnational financial transactions.
The above list is exhaustive and all listed items are to be considered as covered by the flat rate and cannot
be reported under any other cost category.
EXAMPLE on 15% flat on direct staff costs
Eligible reported Staff costs = 36.000, 00€

Flat rate for Office & administrative costs = 15%
Eligible reported Office & administrative costs =
36.000,00 € * 15% = 5.400,00 €
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Part of 40% FLAT
In case the beneficiary selected the 40% flat rate for the calculation of eligible direct costs other than
direct staff costs, office and administrative costs are included as part of the remaining eligible costs of an
operation in the 40% flat. If the 40% flat rate is used, there will be only two cost categories in the project:
1) Staff costs and 2) The remaining eligible costs covering costs for office and administrative expenditure,
travel and accommodation, external expertise and services, equipment, infrastructure and works.
Beneficiaries are not requested to document that expenditure for office and administrative costs have
been incurred and paid nor to justify the applicable rate chosen. Therefore, no documentation on office
and administrative costs needs to be provided to the controller.
In case direct staff costs used as a basis for determining office and administrative expenditure are found
to be ineligible, the amount of office and administrative expenditure must be recalculated and reduced
accordingly.
The documentation of real costs will be requested for other cost categories used as a basis for the flat
rate calculation (Staff costs).
Verification against double-financing are requested (e.g., checking that other cost categories do not
include costs covered under the 15% or 40% flat option).
5.6.3. Travel and accommodation costs

Travel and accommodation costs refer to the expenditure on travel and accommodation of the staff of
the beneficiary for missions necessary for the project implementation.
The Programme reimburses travel and accommodation costs through a flat rate of 15% of eligible direct
staff costs or as part of the 40% flat on eligible direct staff costs.
15% FLAT
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Travel and accommodation costs, regardless whether such costs are incurred and paid inside or outside
the Programme area, shall be limited to the following cost elements:
(a) travel costs (such as tickets, travel and car insurance, fuel, car mileage, toll, and parking fees);
(b) the cost of meals;
(c) accommodation costs;
(d) visa costs; and
(e) daily allowances (per diems).
Any cost element listed in points (a) to (d) covered by a daily allowance shall not be reimbursed in addition
to the daily allowance (per diems).
The above list is exhaustive and all listed items are to be considered as covered by the flat rate and cannot
be reported under any other cost category.
EXAMPLE on 15% flat on direct staff costs
Eligible reported Staff costs = 40.000, 00€

Flat rate for Travel & accommodation costs =
15%
Eligible reported Travel & accommodation
costs = 40.000,00 € * 15% = 6.000,00 €
Part of 40% FLAT
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direct staff costs, the 40% Flat also covers travel and accommodation costs. If the 40% flat rate is used,
there will be only 2 cost categories in the project: 1) Staff costs and 2) The remaining eligible costs covering
costs for office and administrative expenditure, travel and accommodation, external expertise and
services, equipment, infrastructure and works.
Beneficiaries are not requested to document that expenditure for travel and accommodation costs have
been incurred and paid nor to justify the applicable rate chosen. Therefore, no documentation on travel
and accommodation costs needs to be provided to the controller.
Verification against double-financing are requested (e.g., checking that other cost categories do not
include costs covered under the 15% or 40% flat option).
In case direct staff costs used as a basis for determining travel and accommodation costs are found to be
ineligible, the amount of travel and accommodation costs must be recalculated and reduced accordingly.
Daily allowances must be in line with the national legislation or internal rules of the partner’s
organisation.
5.6.4. External expertise and services costs

External expertise and service costs shall be limited to the following services and expertise provided by a
public or private body or a natural person, other than the beneficiary, and all partners of the operation:
(a) studies or surveys (such as evaluations, strategies, concept notes, design plans, handbooks);
(b) training;
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(c) translations;
(d) development, modifications and updates to IT systems and website;
(e) promotion, communication, publicity, promotional items and activities or information linked to an
operation or to a Programme as such;
(f) financial management;
(g) services related to the organisation and implementation of events or meetings (including rent, catering
or interpretation);
(h) participation in events (such as registration fees);
(i) legal consultancy and notarial services, technical and financial expertise, other consultancy and
accountancy services;
(j) intellectual property rights;
(k) verifications (carried out by national controllers of the project);
(l) the provision of guarantees by a bank or other financial institution where required by Union or national
law or in a programming document adopted by the monitoring committee;
(m) travel and accommodation for external experts, speakers, chairpersons of meetings and service
providers;
(n) other specific expertise and services needed for operations.
This list is exhaustive. Cost items accounted under the external expertise and services cost category
cannot be reimbursed under any other cost category.
The Programme reimburses costs under this category on a real cost basis or as part of 40% flat rate on
direct staff costs.
REAL COST
In addition to the general eligibility requirements, the following applies:
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● External expertise and services must be clearly and strictly linked to the project and be essential
for its effective implementation;
● Eligibility of costs for external expertise and services is subject to the full respect of EU, national
and Programme procurement rules;
● Where applicable, deliverables produced by experts or service providers must respect the relevant
branding requirements;
● External expertise and services have to be duly foreseen in the Application Form (description is
visible in work packages and/or budget) in order to be considered as eligible and the respective
budget allocated to the Project Partner (changes are possible in line with project modification
rules);
● Complementary activities to events (e.g. site visits) must have clear and demonstrable project
relevance, otherwise costs linked to them are not eligible;
● Travel and accommodation costs of external speakers and external participants in project
meetings and events or related to the staff of associated partners must be incurred and paid by
project partners and have to be accounted under this cost category. Such costs must comply with
applicable national and institutional rules about travel and accommodation;
● Alcohol may be eligible given that it’s part of a meal and provided that it is in line with relevant
national and institutional rules of the project partner;
● Sub-contracting between partners of the same project is not allowed;
● All costs of external expertise and services which are not part of an infrastructure contract (e.g.,
feasibility studies, environmental impact assessments, building permissions, etc.) but which are
linked to the realisation of an infrastructure should be included in this cost category.
The following documents should be provided to the controllers:
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● Evidence of the selection procedure (if applicable), in line with EU, national or Programme
procurement rules, depending on the amount contracted and the type of beneficiary;
● Contract/order (if applicable) form laying down the services to be provided, with clear reference
to the operation and the Programme. For experts paid on the basis of a daily fee, such a fee
together with the number of days contracted and the total amount of the contract must be
provided. Any changes to the contract must comply with the applicable procurement rules and
must be documented;
● An invoice or a request for reimbursement providing all relevant information in line with the
applicable accountancy rules, as well as references to the operation and the Programme and a
detailed description of the services provided in line with the contents of the contract. For experts
paid on the basis of a daily/hourly fee, the invoice must include a clear quantification of the
days/hours charged, price per unit and total price;
● Deliverables produced (e.g. studies, promotional materials) or, where applicable, documentation
of the delivery (e.g. in case of events: agenda, list of participants, photo-documentation, etc.);
● In case of travel and accommodation costs of external experts and associated partners, Invoices
or documents of equivalent probative value (hotel invoices, bus/train/plane tickets, etc.) including
proof of payments (e.g. bank statements) and proof of reimbursement (in case the expenses were
pre-financed). The documented evidence of their participation (such as signed list of participants)
should also be provided in line with what obligatory according to national/institutional rules of the
partner organisation (including, where applicable, authorisation of the mission and/or mission
report signed by the travelling person);
● Proof of payment (e.g. extract from a reliable accounting system of the beneficiary, bank
statement);
● Accounting records that prove the separate accounting system for the project from the usual
activity of the Organisation/Institution.
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Part of 40% FLAT
direct staff costs, external expertise and services costs are included as part of the remaining eligible costs
of an operation in the 40% Flat. If the 40% flat rate is used, there will be only 2 cost categories in the
project: 1) Staff costs and 2) The remaining eligible costs covering costs for office and administrative
expenditure, travel and accommodation, external expertise and services, equipment, infrastructure and
works.
In case external expertise and service are part of the 40% flat, beneficiaries are not requested to document
that expenditure have been incurred and paid. Therefore no documentation on external expertise and
service costs needs to be provided to the controller.
Verifications that the calculation is correct (flat applies on a correct real cost category used as a basis for
the calculation) and verification against double-financing are requested (e.g., checking that other cost
categories do not include costs covered under the flat option).
5.6.5. Equipment costs
This category includes costs for equipment purchased, rented or leased by the beneficiary other than
those covered under office and administrative cost category, which is necessary for the implementation
of the project. This includes costs of equipment already in possession by the beneficiary and used to carry
out project activities.
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Costs of equipment shall be limited to the following:
(a) office equipment;
(b) IT hardware and software;
(c) furniture and fittings;
(d) laboratory equipment;
(e) machines and instruments,
(f) tools or devices;
(g) vehicles; and
(h) other specific equipment needed for the project.
This list is exhaustive. Cost items reported under this cost category cannot be reimbursed under any other
cost category.
Costs for the purchase of second-hand equipment may be eligible subject to the following conditions:
a) no other assistance has been received for it from the Interreg funds or from other EU funds;
b) its price does not exceed the generally accepted price on the market in question; and
c) it has the technical characteristics necessary for the operation and complies with applicable norms
and standards.
direct staff costs.
REAL COST
In addition to the general eligibility requirements, the following applies:
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● Equipment items can only be funded by the Programme if no other EU funds have contributed
towards their financing;
● Equipment must be clearly linked to the project and be essential for its effective implementation
(or it is a project output);
● Equipment is eligible if it is foreseen in the Application Form (description is visible in work packages
and/or budget). Changes are possible in line with project modification rules;
● The relevant procurement rules must be respected and properly documented;
● Publicity rules must be observed, where applicable (The equipment shall be properly
labelled/plaqued complying with the reference to the Programme. In line with national/regional
provisions, equipment must be registered in special registers.);
● Costs of equipment which is purchased, rented or leased from another beneficiary are not eligible.
When reporting expenditure on equipment, the following points should be considered:
● If the equipment is used solely for the purpose of the project, will be fully depreciated before the
end date of the project and was purchased and paid for within the eligible period, the full purchase
cost should be reported;
● If the equipment was purchased before the project was approved, a pro-rata depreciation will be
applied. Only the value of the depreciation incurred during the project timeframe is eligible;
● If the equipment is purchased during the project lifetime but the depreciation plan is longer than
the project duration, a pro-rata depreciation will be applied. Only the value of the depreciation
incurred during the project timeframe is eligible (assuming the equipment is used 100% on the
project);
● If non-depreciable equipment (e.g., low-value asset) is purchased, the full purchase cost of the
equipment should be reported where the equipment is used 100% on the project;
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● If the equipment is rented or leased, depreciation does not apply, i.e., full cost is reported where
the equipment is used 100% on the project;
● If the equipment is purchased by the partner organisation, but is only partially used for the project,
only the share related to use for the project may be reported. This share must be calculated
according to a justified and equitable method in line with legislation or the partner organisation’s
general accounting policy;
Table 10: Equipment options
If the equipment represents Non Depreciable Depreciable Purchased Rented /

a core component of and it is before leased
essential for the project project
output (e.g., the purchase of approval
a laboratory machine for the
purpose of research activities
in the project, or the
purchase of fixed assets
necessary for infrastructure),
then the full cost of the item
as approved by the
Programme can be reported
(under equipment cost
category). EQUIPMENT
Not core component of Full cost Pro rata Pro rata Full cost
project output used 100% for
the project
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Not core component of Pro rata Pro rata Pro rata Pro rata
project output partially used
for the project
As core component of the Full cost Full cost Full Full cost
project output remainder
● If not stated otherwise by National or internal rules of the beneficiary, the following calculation
method has to be applied in case of assets subject to depreciation:
Cost of the item x % of depreciation x timeframe of usage during the project = annual eligible
amount.
The % of depreciation is extrapolated from the relevant applicable tables to be applied according
to National legislation.
In case the real usage timeframe or the reporting period is not equal to a solar year, but to days
or months, the calculation has to be made on a daily/monthly basis:
Annual eligible amount /360 x days of usage = eligible amount
Annual eligible amount/12 x months of usage = eligible amount
● As soon as the physical implementation of projects involving physical investment starts or

purchased equipment is installed, beneficiaries are requested to displaying durable plaques or
billboards clearly visible to the public;
● Equipment is eligible if it is not covered by the office and administration costs, for instance the
purchase of consumables not falling under office and administrative costs which are necessary
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for the use of laboratory equipment or machines and instruments is eligible and have to
reported under this cost category;
● If the equipment is part of an investment (productive investment or an investment in

infrastructure) durability has to be ensured;
● The cost of maintenance/repair service contracts related to the equipment has to be allocated
and reported under external expertise and services (as other specific services needed for the
project);
● On-site verification of equipment is based on risk based methodology applied by controllers; In

line with national/regional provisions, equipment must be registered in special registers, if
applicable.
● Evidence of the selection procedure (if applicable), in line with applicable EU, national or
Programme procurement rules, depending on the amount contracted and the type of beneficiary
;Contract or written agreement laying down the supplies to be provided and any services related
to installation and/or maintenance of supplies Any changes to the contract must comply with the
applicable procurement rules and must be duly documented.
● Invoice (or a supporting document having equivalent probative value to invoices, in case of
depreciation) providing all relevant information carried out in line with the contents of the
contract, the applicable national accountancy rules and internal accountancy policies of the
beneficiary and, where applicable, bearing references to the project and the Programme;
● In case depreciation applies, a calculation scheme of depreciation;
● In case the equipment is charged pro-rata, the method set in place for allocating the share of use
in the project;
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● Proof of existence (pictures, delivery note, etc.);
statement);
activity of the Organisation/Institution.
Part of 40% FLAT
direct staff costs, equipment costs are included as part of the remaining eligible costs of an operation in
the 40% Flat. If the 40% flat rate is used, there will be only 2 cost categories in the project: 1) Staff costs
and 2) The remaining eligible costs covering costs for office and administrative expenditure, travel and
accommodation, external expertise and services, equipment, infrastructure and works.
In case equipment is part of the 40% flat, beneficiaries are not requested to document that expenditure
have been incurred and paid. Therefore no documentation on equipment costs needs to be provided to
the controller.
Verifications that the calculation is correct (flat applies on a correct real cost category used as a basis for
the calculation) and verification against double financing are requested (e.g., checking that other cost
5.6.6. Costs for infrastructure and works

Costs for infrastructure and works shall be limited to the following:
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(a) purchase of land;
(b) building permits;
(c) building material;
(d) labour; and
(e) specialised interventions (such as soil remediation, mine-clearing).
This list is exhaustive.
Cost items accounted under this cost category cannot be reimbursed under any other cost category.
A work it is intended as the outcome of building or civil engineering works taken as a whole, which is
sufficient in itself to fulfil an economic or technical function 29. Costs for Infrastructure and works may
either refer to an object (e.g. a building) that will be set up ex-novo or to the adaptation of an already
existing infrastructure.
Costs of feasibility studies, environmental impact assessments, architectural or engineering activities and
any other expertise needed for the realisation of the infrastructure, shall be allocated under the cost
categories Staff costs or External expertise and services costs (depending whether carried out internally
by the beneficiary or with the support of external suppliers).
direct staff costs.
REAL COST
In addition to the general eligibility requirements the following applies:
● Costs for infrastructure and works must be clearly linked to the project and be essential for its
effective implementation;
29 Article 2 of Directive 2014/24/EU.
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● Costs for infrastructure and works have to be in line in the approved AF;
● In respect of the purchase of land, this is limited to a maximum of 10% of the total project budget,
for derelict sites and for those formerly in industrial use (e.g., brownfields) which comprise
buildings, that limit shall be increased to 15 %;
● Full cost for infrastructure and works within the project is eligible insofar as it is fully justified as
part of project’s activities, i.e. no depreciation is necessary;
● Costs for infrastructure and works outside the Programme area are not eligible;
● In case of infrastructure and works that are part of a larger infrastructural investment funded
through other sources, the part realised by the project partner must be clearly and unequivocally
identifiable;
● Costs of infrastructure and works are eligible if no other Union or national funds have contributed
towards financing of the same expenditure (no double funding is permissible);
● Eligibility of costs for infrastructure and works is subject to the respect of applicable procurement
rules (EU, national and Programme procurement rules);
● Depending on the nature of the intervention to be carried out, all compulsory requirements set by
EU and national legislation on environmental policies, must be fulfilled;
● Where applicable, works must have been previously authorised by national/regional/local

authorities (building permission);
● The land and/or buildings where the works will be carried out must be in the ownership of the
beneficiary or the beneficiary must have set in place long-term legally binding arrangements in
order to fulfil durability (including maintenance) requirements;
● The purpose and ownership of the infrastructure cannot be changed for at least 5 years after the
final payment to the beneficiary;
● Where applicable, infrastructure and works realised by the project must respect the relevant
publicity requirements;
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● On-site verification of infrastructure and works is based on risk based methodology applied by
controllers. The existence of infrastructure and works realised by the project and their clear
identification to the project is verified on-the-spot (if applicable) for each realised item.
● Infrastructure and construction works must be the result of cross-border cooperation activities
(such as joint planning, design, decisions, and implementation) specifically directed at improving
the development of the Programme area. The cross-border dimension and added value must be
substantiated in the application form and are assessed during evaluation process.
● An operation comprising physical investment (infrastructure) or a productive investment shall

pay back the ERDF received proportionate to the period of non-compliance if, within five years
of the final payment to the project, it is subject to:
o a cessation or transfer of a productive activity outside the NUTS level 2 region in which
it received support;
o a change in ownership of an item of infrastructure which gives to a firm or a public body

an undue advantage;
o a substantial change affecting its nature, objectives or implementation conditions which

would result in undermining its original objectives.
The Member State may reduce the time limit to 3 years in cases concerning the maintenance of
investments or jobs created by SMEs.
● In respect of projects where their total cost exceeds EUR 100.000,00 for any infrastructure and
work (as for the case of purchased equipment), projects are required to put up a durable plaque
or billboard visible to the public on site. The plaque or billboard should be put up as soon as the
physical implementation of the project involving physical investment starts (or the equipment
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is purchased). The plaque or billboard should present the emblem of the Union in accordance
with EU technical characteristics.
● Legal documents specifying the ownership or long-term arrangement for the land and/or buildings
where the works will be carried out;
● Where applicable, necessary permissions for the execution of the works, issued by the
national/regional/local relevant authorities;
● Evidence of the appropriate selection procedure, in line with EU, national or Programme
procurement rules, depending on the nature of the concerned works, the amount contracted and
the type of beneficiary.
Infrastructure and construction works shall be compliant with applicable European, National and
internal procurement rules, including e.g. feasibility studies, environmental impact assessments,
building permissions, etc. The above-mentioned authorisations have to be possessed at the
moment of the application or at least within 1 month of the closure of the Call;
● Contract or written agreement laying down the infrastructure/works and supplies and services
connected to execution of works (forming a part of works contract) to be provided with a clear
reference to the project and the Programme. For contracts including also a daily/hourly fee, such
fee together with the number of days/hours contracted and the total amount of the contract must
be provided. Any changes to the contract must comply with the applicable procurement rules and
must be documented;
● Invoice or interim payment certificate providing all relevant information in line with the applicable
accountancy rules as well as references to the project and the Programme and a detailed
description of infrastructure and works carried out in line with the contents of the contract and in
line with national legislation related to works/infrastructure;
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statement);
activity of the Organisation/Institution;
● Proof of respect of Programme publicity requirements rules and where relevant, EU and national
legislation in terms of environmental impact.
Part of 40% FLAT
direct staff costs, infrastructure and works costs are included as part of the remaining eligible costs of an
operation in the 40% Flat. If the 40% flat rate is used, there will be only 2 cost categories in the project: 1)
Staff costs and 2) The remaining eligible costs covering costs for office and administrative expenditure,
travel and accommodation, external expertise and services, equipment, infrastructure and works.
In case infrastructure and works costs are part of the 40% flat, beneficiaries are not requested to
document that expenditure have been incurred and paid. Therefore no documentation on infrastructure
and works needs to be provided to the controller.
Verifications that the calculation in correct (flat applies on a correct real cost category used as a basis for
the calculation) and verification against double-financing are requested (e.g., checking that other cost
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5.7. Reimbursement of funds
The Programme applies the reimbursement principle, according to which each beneficiary must fully pre-
finance its project expenditure.
Model and timeframe for the reimbursement of funds
The disbursement of funds by the MA is subject to availability of funding (the EC makes necessary funds
available), it takes place as soon as possible and within 80 days from the submission of the project report
and the related payment request/application. Please be aware, that any clarification round respectively
request for further information or documentation by JS/MA will interrupt this deadline and will result in
later ERDF reimbursement to projects.
Should no funds be available, the LP will be duly notified and – if possible - a provisional date for the
expected payment announced.
In case of Croatian LP, the MA will transfer:
 the total share of ERDF due to Croatian partners to the Croatian LP;
 the total share of ERDF due to Italian partners AND the total share of National co-financing (Fondo
di Rotazione) of the Italian PPs to the Italian PP with the highest budget among the Italian PPs
within the project.
In case of Italian LP, the MA will transfer:
 the ERDF amount and the amount of the due Italian National co-financing (Fondo di Rotazione)
contributions to the LP.
After receipt of funds from the MA, the LP and the Italian PP with the highest budget are obliged to
transfer in time and in full the share of ERDF which corresponds to each PP, including the national co-
financing (Fondo di Rotazione) for the Italian PPs entitled to it. No amount shall be deducted or withheld
and no specific charge or other charge with equivalent effect shall be levied, which would reduce that
amount for the PPs.
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5.8. Conversion into Euro
Financial reporting of a project shall take place in Euro and the Programme will reimburse ERDF
contributions in Euro.
All expenditures incurred and paid in a currency other than Euro, shall be converted by the beneficiary
using the monthly accounting exchange rate of the European Commission in the month during which that
expenditure was submitted for verification by the concerned beneficiary to its national controller.
The date of submission refers to the day in which the beneficiary submits for the first time to its controller
the partner report concerning a certain expenditure. Further submissions of missing documents,
clarifications etc. on that expenditure shall not be considered. The date of submission is documented in
Jems and the conversion into Euro is automatically carried out by the monitoring system.
5.9. Recovery of funds
The MA shall ensure that any amount paid as a result of an irregularity is recovered from the LP and PPs
shall repay to the lead partner any amounts unduly paid.
Therefore, the LP shall ensure that the concerned PP repays the LP any amounts unduly paid, as specified
in the partnership agreement. The amount to be repaid can be withdrawn from the next payment to the
LP or the remaining payments. In case of closed projects, the LP is obliged to repay the unduly paid out
funds to the MA.
Unduly paid out funds can be discovered by various entities, mainly the Programme bodies, the European
Commission (EC), the European Anti-Fraud Office (OLAF), the European Court of Auditors (ECA) or other
national public auditing bodies and this process implies the repayment of the subsidy in whole or in part
from the LP.
In case the LP does not succeed in securing repayment from the concerned PP, or if the MA does not
succeed in securing repayment from the LP, the concerned Member State on whose territory the
concerned partner is located shall reimburse the MA the amount that was unduly paid to that partner. In
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turn, the concerned Member State shall be entitled to claim the unduly paid funds from that partner. The
recovery of funds follows the path below:
Image 8: Reimbursement flow
MS MA LP PP
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6. MONITORING AND REPORTING - Coming soon
6.1. General overview of monitoring
6.2. General overview of reporting
6.3. Monitoring and reporting at Partner level
6.4. Monitoring and reporting at Project level
6.5. Reporting periods
6.6. Assessment of the reports by JS
6.7. Project mid-term review
6.8. Performance framework and de-commitment
6.9. Durability and ownership of outputs and equipment
7. PROJECT MODIFICATIONS AND FLEXIBILITY RULES - Coming soon

7.1. General principles (types of project modifications)
7.2. Minor modifications
7.3. Major modifications
8. PROJECT CLOSURE- Coming soon

8.1. Final progress report
8.2. Final quality assessment
8.3. Last application for reimbursement
8.4. Formal closure process
8.5. Retention and availability of project related documents
9. CONTROLS AND AUDITS- Coming soon

9.1. National control systems
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9.2. Controls performed by the MA/JS
9.3. Audits by the Audit Authority (AA) and Group of Auditors (GoA)
9.4. Audit trail
9.5. Avoidance of double funding
108
10. WHERE TO FIND ASSISTANCE
The Programme Implementation Manual is complemented with several practical guidance documents. A
reference to them is made in the PIM, where relevant. These documents give you detailed and technical
information and should be read together with the PIM. In addition, frequently asked questions or videos
further explaining the Programme’s rules and practices, on our website or during Programme events.
The Interreg VI A Italy – Croatia Joint Secretariat (JS) provides assistance and support to all applicants and
projects at all stages of the project lifecycle. Any communication between the JS and beneficiaries shall
take place only between the Lead Applicant or Lead Partner and the JS staff via e-mail, telephone and face
to face (or online or hybrid) meetings using the following contacts details:
INTERREG VI-A Italy–Croatia 2021-2027

Programme Joint Secretariat
JS Headquarters: JS Antenna in Zadar
c/o Veneto Region, Italy – Croatia c/o Ministry of Regional Development and EU
Managing Authority Funds
Dorsoduro 3494/a – 30123 Venice, Italy, Franka Lisice 77, 23000 Zadar - Croatia
e-mail:JS.ItalyCroatia@regione.veneto.it e-mail: js.it-hr.antenna@mrrfeu.hr
The Programme language is English: all official communications are conducted in English and all
Programme documents are produced in English only. The project application and reporting is also done
in English.
An Electronic data exchange systems, Jems, is used for all steps of the projects application and
implementation. All projects and Programme bodies use the system.
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If a new version of the PIM is published on the Programme website, it becomes valid from that point
onward. The latest version of the PIM should always be used.
According to the Lead Partner principle, each project partnership shall appoint one organization acting as
the L P who shall take full financial and legal responsibility for the implementation of the entire project
towards the Programme bodies.
All relevant documentation and information for beneficiaries will be available on the Interreg VI A Italy –
Croatia Programme web site (https://www.italy-croatia.eu/web/it-hr-interreg-2021-2027). The website is
the one-stop-shop for finding Programme-related information: call for proposals’ documents and tools,
timeline of calls, news and information on events, conditions for the submission of project proposals,
assessment of proposals, changes of relevant documentation, JS staff answers to frequently asked
questions, as well as other relevant information.
10.1. Programme Events

Different types of events are organised by the Programme for each call for proposals in order to inform
and support potential applicants. The content and timing of the events may vary according to each call
for proposals.
10.2. Information days

Information days are also organised by the Programme on the occasion of each call opening to inform
potential applicants about the Programme, the content of the Call for Proposals (topics addressed,
objectives and specific expectations of the Programme towards the call). Depending on needs, this
informative session can be attended onsite or online.
During these infodays, participants receive information on the key steps and tools of the call, and the
elements relating to the application and assessment phases.
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The participation to this sessions is strongly recommended for any applicant potentially interested in the
Call, in order to limit as much as possible the submission of proposals that would not be adapted to the
Programme's expectations.
10.3. Meetings
Meeting with Applicants/Beneficiaries (application phase)
Within the limit established by the Programme at the time of the publication of the call, a single, non-
compulsory, individual meeting per project idea is organized by the JS during the application phase of a
call and aim to support applicants in the construction of their proposal. These meetings are generally
organized online and consist of a one hour session focusing on the key points in the preparation of a
proposal (partnership, work plan, eligibility of expenditure, etc.).
ATTENTION!
Consultations are no pre-assessments and will not be based on the Application Form or parts of it. The
JS will clarify general principles but not advise on concrete outputs, activities or deliverables nor e.g.
the admissibility or the eligibility of the project proposal.
Meetings with Beneficiaries (in implementation phase)

Individual meetings may be provided by the JS when requested by the Lead Partners. These meetings aim
at providing technical advice focusing on the project implementation (work plan, financial issues and
similar). The assigned JS Project Manager will provide individual meetings to the Lead Partner when
needed and justified. The Lead Partner will be provided with special guidance regarding amendment of
Subsidy contract, project changes, reporting and various important administrative issues. The Lead
Partner has to provide all the information requested by the provisions of the Subsidy contract to the
assigned PM at the JS in time before the meeting. The Lead Partner is responsible to inform the JS without
delay on any serious problems encountered during the project implementation.
111
10.4. Other events
Thematic seminars
Thematic seminars may be organised to facilitate the understanding of the Programme's architecture, to
encourage the sharing of experience and the transfer of results. Speakers from outside the MA/ JS may
also contribute to this type of seminars.
Depending on the needs, the thematic seminars may be accessible online or onsite.
Training activities for beneficiaries

The MA/ JS are committed to organise and implement training activities (e.g. workshops, trainings,
seminars, etc.) on specific implementation topics such as project management, reporting requirements,
communication, capitalisation and networking to strengthen the capacity of beneficiaries to successfully
implement the projects.
Events organized by beneficiaries

Furthermore, the JS may visit selected events of the projects (e.g. kick-off, media trip, mid-term, final
conference and similar) or project meetings depending on the resources available within the Programme
both in terms of funds (TA) and personnel.
112

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INTERREG ITALY-CROATIA

PROGRAMME 2021 – 2027

1st Call for Proposals

1. PROGRAMME BASIC FEATURES .............................................................................................................. 6

1.1. Programme overview ............................................................................................................................................... 6

1.2. Programme area ...................................................................................................................................................... 8

1.3. Programme budget and co-financing ....................................................................................................................... 9

1.4. Programme management structures ...................................................................................................................... 10

1.5. Use of Jems ............................................................................................................................................................ 11

1.6. Types of projects – Standard, Small-scale projects, OSI .......................................................................................... 12

1.7. Programme intervention logic and cooperation criteria ......................................................................................... 13

1.8. Synergies and complementarities with EU policies................................................................................................. 16

1.9. Horizontal and cross-cutting principles .................................................................................................................. 20

1.10. Greening principles ................................................................................................................................................ 22

2. LEGAL FRAMEWORK ............................................................................................................................. 25

2.1. Public procurement rules ....................................................................................................................................... 26

2.2. State Aid ................................................................................................................................................................ 30

2.3. Complaints and litigation ....................................................................................................................................... 37

2.4. GDPR, General Data Protection Regulation ............................................................................................................ 39

2.5. Anti-fraud policies .................................................................................................................................................. 39

3. PROJECT GENERATION AND START ....................................................................................................... 41

3.1. Project’s lifecycle ................................................................................................................................................... 41

3.2. Project generation.................................................................................................................................................. 44

3.3. Conditions clearing and contracting ....................................................................................................................... 53

3.4. Lead Partner principle and project start ................................................................................................................. 54

4.2. Project branding, information and visibility rules ................................................................................................... 62

4.3. Project communication strategy ............................................................................................................................ 68

5. FINANCIAL MANAGEMENT ................................................................................................................... 71

5.1. General eligibility requirements ............................................................................................................................. 71

5.2. Hierarchy of rules regarding the eligibility of expenditures .................................................................................... 72

5.3. Time-wise eligibility of expenditure ....................................................................................................................... 73

5.4. Non-eligible expenditure ........................................................................................................................................ 74

5.5. Simplified Cost Options (SCOs) ............................................................................................................................... 75

5.6. Specific cost category provisions ............................................................................................................................ 78

5.7. Reimbursement of funds ...................................................................................................................................... 104

5.8. Conversion into Euro ............................................................................................................................................ 105

5.9. Recovery of funds ................................................................................................................................................ 105

6. MONITORING AND REPORTING - COMING SOON ............................................................................... 107

6.1. General overview of monitoring .......................................................................................................................... 107

6.2. General overview of reporting ............................................................................................................................. 107

6.3. Monitoring and reporting at Partner level............................................................................................................ 107

6.4. Monitoring and reporting at Project level ............................................................................................................ 107

6.5. Reporting periods................................................................................................................................................. 107

6.6. Assessment of the reports by JS ........................................................................................................................... 107

6.7. Project mid-term review ...................................................................................................................................... 107

6.8. Performance framework and de-commitment ..................................................................................................... 107

7. PROJECT MODIFICATIONS AND FLEXIBILITY RULES - COMING SOON .................................................. 107

7.1. General principles (types of project modifications) .............................................................................................. 107

7.2. Minor modifications ............................................................................................................................................. 107

7.3. Major modifications ............................................................................................................................................. 107

8. PROJECT CLOSURE- COMING SOON .................................................................................................... 107

8.1. Final progress report ............................................................................................................................................ 107

8.2. Final quality assessment ...................................................................................................................................... 107

8.3. Last application for reimbursement ..................................................................................................................... 107

8.4. Formal closure process ......................................................................................................................................... 107

8.5. Retention and availability of project related documents ...................................................................................... 107

9. CONTROLS AND AUDITS- COMING SOON ........................................................................................... 107

9.1. National control systems ...................................................................................................................................... 107

9.2. Controls performed by the MA/JS ........................................................................................................................ 108

9.4. Audit trail ............................................................................................................................................................. 108