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Version 1 2 - 26.0928.10.2013
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FICHE NO 17 C
MANAGEMENT AND CONTROL SYSTEMS –IMPLEMENTING ACT
VERSION 1 2 – 26/0928/10/2013
Regulation Article
Common Provisions Regulation (CPR)
Article 113bis (7) on model for system
description, audit report and audit opinion on
the system description
This document is provisional, without prejudice to the on-going negotiations in the Trilogues
between the European Parliament and the Council (in line with the principle that "nothing is
agreed until everything is agreed"). This document is a draft that shall be adjusted following
the expert meeting.
It does not prejudge the final nature of the basic act, nor the content of any delegated or
implementing act that may be prepared by the Commission.
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1. EMPOWERMENT
Article 113bis (7) of the CPR sets out that:
“The Commission shall adopt, by means of implementing act, in accordance with the
examination procedure referred to in Article 143(3), uniform conditions on the model for the
report and opinion of the independent audit body and the description of the functions and
procedures in place for the managing authority and, where appropriate, the certifying
authority.”
This document is based on the most recent compromise text, and is a provisional text, without
prejudice to the on-going negotiations (in line with the principle that "nothing is agreed until
everything is agreed").
2. MAIN OBJECTIVES AND SCOPE
The implementing act sets out the models for the description of the functions and procedures
in place for the managing authority and, where appropriate, the certifying authority, the report
and the audit opinion thereon in view of the designation process carried out by the Member
State.
3. MAIN ELEMENTS
Description of the functions and procedures in place for the managing authority and,
where appropriate, the certifying authority
Description of the functions and procedure in place
Article 62 of the CPR contains the general principles of management and control systems
“Management and control systems shall, in accordance with art. 4(8), provide for:
(a) a description of the functions of each body concerned in management and control, and the
allocation of functions within each body;
(b) compliance with the principle of separation of functions between and within such bodies;
(c) procedures for ensuring the correctness and regularity of expenditure declared;
(d) computerised systems for accounting, for the storage and transmission of financial data and
data on indicators, for monitoring and for reporting;
(e) systems for reporting and monitoring where the responsible body entrusts execution of tasks
to another body;
(f) arrangements for auditing the functioning of the management and control systems;
(g) systems and procedures to ensure an adequate audit trail;
(h) the prevention, detection and correction of irregularities, including fraud, and the recovery
of amounts unduly paid, together with any interest on late payments.
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Annex XX (Political Agreement – Coreper of 26/06/2013) of the CPR contains the
designation criteria for the managing and certifying authority:
“1. Internal control environment
(i) Existence of an organisational structure covering the functions of managing and certifying
authorities and the allocation of functions within each of them, ensuring that the principle of
separation of functions, where appropriate, is respected.
(ii) Framework for ensuring, in case of delegation of tasks to intermediate bodies, the definition
of their respective responsibilities and obligations, verification of their capacities to carry out
delegated tasks and the existence of reporting procedures.
(iii) Reporting and monitoring procedures for irregularities and for the recovery of amounts
unduly paid.
(iv) Plan for allocation of appropriate human resources with necessary technical skills, at
different levels and for different functions in the organisation.
2. Risk management
Taking into account the principle of proportionality, a framework for ensuring that an
appropriate risk management exercise is conducted when necessary, and in particular, in the
event of major modifications to the activities.
3. Management and Control activities
A. Managing authority
(i) Procedures regarding grant applications, appraisal of applications, selection for funding,
including instructions and guidance ensuring the contribution of operations to achieving the
specific objectives and results of the relevant priority axes in accordance with the provisions of
Article 114(3)(a)(i).
(ii) Procedures for management verifications including administrative verifications in respect of
each application for reimbursement by beneficiaries and the on-the-spot verifications of
operations.
(iii) Procedures for treatment of applications for reimbursement by beneficiaries and
authorisation of payments.
(iv) Procedures for a system to collect, record and store in computerised form data on each
operation, including, where appropriate, data on individual participants and a breakdown of
data on indicators by gender when required, and to ensure that systems security is in line with
internationally accepted standards.
(v) Procedures established by the managing authority to ensure that beneficiaries maintain
either a separate accounting system or an adequate accounting code for all transactions relating
to an operation.
(vi) Procedures for putting in place effective and proportionate anti-fraud measures.
(vii) Procedures to ensure an adequate audit trail and archiving system.
(viii) Procedures to draw up the management declaration of assurance, report on the controls
carried out and weaknesses identified, and the annual summary of final audits and controls.
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(ix) Procedures to ensure the provision to the beneficiary of a document setting out the
conditions for support for each operation.
B. Certifying authority
(i) Procedures for certifying interim payment applications to the Commission.
(ii) Procedures for drawing up the accounts and certifying that they are true, complete and
accurate and that the expenditure complies with [applicable Union and national rules] taking
into account the results of all audits.
(iii) Procedures for ensuring an adequate audit trail by maintaining accounting records
including amounts recoverable, recovered and withdrawn for each operation in computerised
form.
(iv) Procedures, where appropriate, to ensure that it receives adequate information from the
managing authority on the verifications carried out, and the results of the audits carried out by
or under the responsibility of the audit authority.
4. Monitoring
A. Managing authority
(i) Procedures to support the work of the monitoring committee.
(ii) Procedures to draw up and submit to the Commission annual and final implementation
reports.
B. Certifying authority
(i) Procedures on the fulfilment of its responsibilities for monitoring the results of the management
verifications and the results of the audits carried out by or under the responsibility of the audit
authority before submitting payment applications to the Commission.”
Report and opinion of the independent audit body
Article 113bis (2) of the CPR requires that the designations of the managing authority and,
where appropriate, of the certifying authority "shall be based on a report and an opinion of an
independent audit body that assesses the compliance of the authorities with the criteria relating to the
internal control environment, risk management, control activities, and monitoring set out in Annex
XX. The independent audit body shall be the audit authority, or another public or private law body
with the necessary audit capacity, which is independent of the managing authority and, where
applicable, of the certifying authority, and which shall carry out its work taking account of
internationally accepted audit standards. Where the independent audit body concludes that the part of
the management and control system, concerning the managing authority or the certifying authority, is
essentially the same as for the previous programming period, and that there is evidence, on the basis
of audit work done in accordance with the relevant provisions of Council Regulation (EC) No
1083/2006, of their effective functioning during that period, it may conclude that the relevant criteria
are fulfilled without carrying out additional audit work."
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4. MAIN CHANGES COMPARED TO THE PERIOD 2007-2013
Description of the functions and procedures in place for the managing authority
and, where appropriate, the certifying authority, opinion and report of the
independent audit body
These 3 documents were already foreseen for the period 2007-2013. Main changes compared
to the period 2007-2013 concern the procedure (role of the Commission) and the authorities
covered by the description and the designation process:
- These documents support the formal designation of the managing authority and where
applicable of the certifying authority as well as the description of their functions, while the
audit authority was also covered for the period 2007-2013.
- There is no systematic transmission of these documents to the European Commission. For
programmes above a threshold (EUR 250 million) the transmission is done upon request from
the European Commission or on a voluntary basis at the initiative of the Member State if
there are significant changes in the functions / management and control system compared to
the previous period, in accordance with the provisions of Articles 113bis(3) and 113bis(4).
5. ANNEXES
Annex 1 – Model for description of the functions and procedures in place for the
managing authority and, where appropriate, the certifying authority
Annex 2 – Model for the opinion and report of the independent audit body on the
designation of the managing authority and, where appropriate, the certifying authority
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Annex 1
Model for description of the functions and procedures in place for the managing
authority and, where appropriate, the certifying authority
1. GENERAL
1.1. Information submitted by:
[Name of the] Member State:
Title of the programme and CCI No: (all operational programmes covered by the
managing authority/certifying authority)
Name of main contact point, including e-mail: (coordinating body responsible for the
description)
1.2. The information provided describes the situation on: (dd/mm/yy)
1.3. System structure (general information and flowchart showing the organisational
relationship between the authorities/bodies involved in the management and control
system)
1.3.1. Managing authority (Name, address and contact point in the managing authority)
Indication whether the managing authority is also designated as certifying authority, in
accordance with Article 113(3) CPR.
1.3.2. Certifying authority (Name, address and contact point in the certifying authority)
1.3.3. Intermediate bodies (Name, address and contact points in the intermediate bodies)
1.3.4. When Article 113(5) applies, indicate how the principle of separation of functions
between the audit and the managing/certifying authorities is ensured.
2. MANAGING AUTHORITY
2.1. Managing authority and its main functions
2.1.1. The status of the managing authority (national, regional or local public body or private
body) and the body in which it is located (in cases where the managing authority and
the certifying authority are both designated in the same body (Article 113(3) of the
CPR), the managing authority shall be a public authority or body)
2.1.2. Specification of the functions and tasks carried out directly by the managing authority
Where the managing authority carries out in addition the functions of the certifying
authority, description of how separation of functions is ensured
2.1.3. Functions formally delegated by the managing authority, identification of the
intermediate bodies and form of delegation (underlying that the managing authorities
maintains the full responsibility for the delegates functions), under Article 113(6) and
(7) of the CPR. The procedures concerning this delegation are described in section 2.2
below.
2.1.4 Description of the procedures for ensuring an effective and proportionate anti-fraud
measures taking account of the risks identified, including reference to the risk
assessment carried out (Article 114(4)(c) of the CPR).
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2.2. Organisation and procedures of the managing authority
2.2.1. Organisation chart and specifications of the functions of the units (including plan for
allocation of appropriate human resources with necessary technical skills). This
information should also cover the intermediate bodies to which some tasks have been
delegated)
2.2.2. Framework to ensuring that an appropriate risk management exercise is conducted
when necessary, and in particular in the event of major modifications to the activities
2.2.3. Description of the following procedures (that should be provided in writing to the staff
of the managing authority and intermediate bodies; date and reference):
2.2.3.1. Procedures to support the work of the monitoring committee.
2.2.3.2. Procedures for appraising, selecting and approving operations and for ensuring
their compliance, for their whole implementation period, with applicable rules
(Article 114(3) of the CPR), including instructions and guidance ensuring the
contribution of operations to achieving the specific objectives and results of the
relevant priority axes in accordance with the provisions of Article 114(3)(a)(i)
and procedures to ensure that operations are not selected where they have been
physically completed or fully implemented before the application for funding
by the beneficiary (including the procedures used by the intermediate bodies
where the appraisal, selection and approval of operations have been delegated,
and the procedures of the managing authority to supervise the effectiveness of
the delegated tasks delegated to the intermediate bodies).
2.2.3.3. Procedures to ensure the provision to the beneficiary of a document setting out
the conditions for support for each operation, including procedures to ensure
that beneficiaries maintain either a separate accounting system or an adequate
accounting code for all transactions relating to an operation.
2.2.3.4. Procedures for the verifications of operations (Article 114(4) to (7) of the
CPR), including for ensuring the compliance of operations with the general
principles and compliance with Union policies, such as the ones related with
partnership and multi-level governance, promotion of equality between men
and women, non-discrimination, sustainable development, public procurement,
State aid and Environment rules., and identification of the authorities or bodies
carrying out such verifications. These verifications concern administrative
verifications in respect of each application for reimbursement by beneficiaries
and on-the-spot verifications on samples of operations1. Where the
management verifications have been delegated to intermediate bodies, the
description includes the procedures applied by the intermediate bodies for
those verifications and the procedures applied by the managing authority to
supervise the effectiveness of the delegated tasks delegated to the intermediate
bodies.
2.2.3.5. Description of the procedures by which applications for reimbursement are
received from beneficiaries, verified, and validated, and by which payments to
beneficiaries are authorised, executed and accounted for, in line with
1 The frequency and coverage of which shall be proportionate to the amount of public support to an
operation and to the level of risk identified by these verifications and audits by the audit authority for the
management and control system as a whole.
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obligations for e-cohesion as from 2016, including flowchart indicating all
bodies involved (including the procedures used by the intermediate bodies
where processing of applications for reimbursement has been delegated, and
the procedures of the managing authorities to supervise the effectiveness of the
delegated tasks delegated to the intermediate bodies), in view of respecting the
deadline of [90] days for payments to beneficiaries under Article 122 of the
CPR.
2.2.3.6. Identification of the authorities or bodies carrying out each step in the
processing of the application for reimbursement.
2.2.3.7. Description of how information will be transmitted to the certifying authority
by the managing authority, where appropriate, including the information on the
follow-up of deficiencies or irregularities detected in the context of
management verifications, audits and controls by Union or national bodies.
2.2.3.8. Description of how information will be transmitted to the audit authority by the
managing authority, where appropriate, including the information on the
follow-up of deficiencies or irregularities detected in the context of audits and
controls by Union or national bodies.
2.2.3.9. Reference to national eligibility rules laid down by the Member State and
applicable to the operational programme.
2.2.3.10. Procedures to draw up and submit to the Commission annual and final
implementation reports, including the procedures for collecting and reporting
reliable data on performance indicators.
2.2.3.11. Procedures for drawing up the management declaration.
2.2.3.12. Procedures for drawing up the annual summary of the final audit reports and
of controls carried out, including an analysis of the nature and extent of errors
and weaknesses identified in systems, as well as corrective action taken or
planned.
2.2.3.13. Procedures for ensuring the compliance of operations with the general
principles and compliance with Union policies, such as the ones related with
partnership and multi-level governance, promotion of equality between men
and women, non-discrimination, sustainable development, public procurement,
State aid and Environment rules.
2.2.3.14. Procedures for ensuring that the actions related with the compliance of ex-ante
conditionalities with implications for the implementation of the programme(s)
are followed-up.
2.2.3.151314. Procedures concerning the communication to staff of the above
procedures, as well of indication of training organised / foreseen and any
guidance issued on the applicable rules (date and reference).
2.5. Audit Trail
2.5.1. Procedures to ensure an adequate audit trail and archiving system, including with
respect to the security of data, taking account of e-cohesion, in accordance with
national rules on the certification of conformity of documents.
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2.5.2. Instructions given on retention of supporting documents by beneficiaries/intermediate
bodies/managing authority (date and reference)
Indication of the retention period
Format in which the documents are to be held
2.6. Irregularities and recoveries
2.6.1. Instructions issued on reporting and correction of irregularities and recording of debt
and recoveries of undue payments (date and reference)
2.6.2. Description of the procedure (including flowchart) to comply with the obligation to
notify irregularities to the Commission in accordance with Article 112(2) of the CPR.
3. CERTIFYING AUTHORITY
3.1. Certifying authority and its main functions
3.1.1. Specification of the functions carried out by the certifying authority
Where the managing authority carries out in addition the functions of the certifying
authority, description of how separation of functions is ensured (see 2.1.2).
3.1.2. Functions formally delegated by the certifying authority (functions, intermediate
bodies, form of delegation). Reference to relevant documents (legal acts with
empowerments, agreements).
3.2. Organisation of the certifying authority
3.2.1. Organisation chart and specification of the functions of the units (including plan for
allocation of appropriate human resources with necessary technical skills). This
information should also cover the intermediate bodies to which some tasks have been
delegated).
3.2.2. Description of the procedures to be provided in writing to the staff of the certifying
authority and intermediate bodies (date and reference).
3.2.3. The status of the certifying authority (national, regional or local public body) and the
body in which it is located.
3.3. Certification of statements of expenditure
3.3.1. Description of the procedure by which payment applications are drawn up, certified and
submitted to the Commission, including procedure to ensure sending of the final
application for interim payment by 31 July following the end of the previous
accounting year.
3.3.2. Description of the steps performed by the certifying authority to ensure fulfilment of
requirements under Article 115 of the CPR
3.3.32. Arrangements for access of the certifying authority to the detailed information on
operations, management verifications and audits held by the managing authority,
intermediate bodies and audit authority
3.4. Accounting system and accounts
3.4.1. Description of the accounting system to be set up and used as a basis for certification of
expenditure to the Commission (Article 115(d) of the CPR)
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Arrangements for forwarding aggregated data to the certifying authority in case of
decentralised system
The link between the accounting system and the information system to be set up (point
54)
Identification of Structural and Investment Funds transactions in case of common
system with other Funds
3.4.2. Description of the procedures in place for drawing up the accounts referred to in article
59(5) of the Financial Regulation (Article 115(b) of the CPR)
Arrangements for certifying the completeness, accuracy and veracity of the accounts
and that the expenditure entered in the accounts complies with applicable Union and
national rules (Article 115(c) of the CPR) and take into account the results of all
audits.
3.5. Recoveries
3.5.1. Description of the system for ensuring the prompt recovery of public assistance,
including Union assistance
3.5.2 Procedures for ensuring an adequate audit trail by maintaining accounting records in
computerised form, including amounts recovered, to be recovered or withdrawn from a
payment application, for each operation, including the recoveries resulting from the
application of Article 61 of the CPR on durability of operations.
3.5.3. Arrangements made to deduct amounts recovered or amounts to be withdrawn from
expenditure to be declared.
4. INFORMATION SYSTEM
4.1. Description of the information systems including flowchart (central or common network
system or decentralised system with links between the systems) for:
collecting, recording and storing, in computerised form data on each operation,
including where appropriate data on individual participants and a breakdown of data
on indicators by gender when required, necessary for monitoring, evaluation, financial
management, verification and audit, including data on individual participants in
operations, where applicable, as required by Article 114(2)(d) of the CPR and by
Article XX of Regulation XX [future delegated act resulting from the empowerment
given by Article 1148() of the CPR];
ensuring that the data referred to in the previous point is collected, entered and stored
in the system, and that data on indicators is broken down by gender where required by
Annex I of the ESF Regulation, as required by Article 114(2)(e) of the CPR;
ensuring that there is a system which records and stores, in computerised form,
accounting records for each operation, and which supports all the data required for
drawing up payment applications and accounts, including records of amounts
recoverable, amounts recovered and amounts withdrawn following cancellation of all
or part of the contribution for an operation or operational programme, as set out in
Article 115(d) of the CPR;
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maintaining accounting records in a computerised form of expenditure declared to the
Commission and the corresponding public contribution paid to beneficiaries, as set out
in Article 115(g) of the CPR;
and the corresponding public contribution paid to beneficiaries, as set out in Article
115(g) of the CPR;
keeping an account of amounts recoverable and of amounts withdrawn following
cancellation of all or part of the contribution for an operation, as established by Article
115(h) of the CPR.
4.2. Description of the procedures to ensure that IT systems security is ensured, in line with
internationally accepted standards;
4.3 Indication as to whether the systems are already operational to gather reliable data on the
matters above-mentioned. If not, indication of the date when they will be operational, in order
to ensure compliance with the provisions referred above and with Article 112(3) of the CPR.
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Annex 2
Model for the opinion and report of the independent audit body on the designation of
the Managing Authority and, where appropriate, the Certifying Authority
Annex 2A. Model opinion issued under Article 113bis(2) of the CPR on the compliance
of the managing authority and the certifying authority with the designation criteria at
Annex XX of the CPR
To …………….. (Member State authority/body)
INTRODUCTION
I, the undersigned, representing (name of the independent audit body under Article 113bis(2)
of the CPR) as the body functionally independent from the managing and certifying
authorities responsible for drawing up a report and opinion setting out the results of an
assessment of the compliance of the managing authority and the certifying authority with the
designation criteria set out in Annex XX of the CPR for …..… [name of operational
programme(s), CCI code number (s)2] (hereafter “the programme(s)),
have carried out an examination in accordance with Article 113bis(2) of the CPR.
SCOPE OF THE EXAMINATION
The examination was based on the description of the management and control systems
received on dd/mm/yyyy from (name of body or bodies submitting the description). In
addition, I have examined further information concerning … (subjects) and interviewed staff
of … (bodies whose staff were interviewed).
The examination covered the managing authority, the certifying authority and (where
appropriate) the following bodies (list only where managing authority or certifying authority
functions have been delegated).
For the following parts of the management and control system3:
-
Concerning the managing authority/certifying authority, I have concluded that the systems are
essentially the same as for the previous programming period and that there is evidence, on the
basis of audit work done in accordance with the relevant provisions of Council Regulation
(EC) No 1083/2006, of their effective functioning during that period. I have therefore
concluded that the relevant criteria are fulfilled without carrying out additional audit work.
OPINION
(Unqualified opinion)
On the basis of the examination referred to above, it is my opinion that the managing
authority and the certifying authority designated for the programme(s) comply with the
2 Where a common system applies to two or more operational programmes a single audit report and opinion may
be given by the independent audit body.
3 Where applicable, in accordance with Article 113bis(2) of the CPR
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designation criteria relating to internal control environment, risk management, management
and control activities and monitoring set out in Annex XX of the CPR.
Or
(Qualified opinion)
On the basis of the examination referred to above, it is my opinion that the managing
authority and / or the certifying authority designated for the programme(s) comply with the
designation criteria relating to internal control environment, risk management, management
and control activities and monitoring set out in Annex XX of the CPR, except in the following
respects4…….
My reasons for considering that this/these body(ies) do(es) not comply with the designation
criterion(a) and my assessment of the seriousness are as follows5:……………………
Or
(Adverse opinion)
On the basis of the examination referred to above, it is my opinion that the managing
authority and / or the certifying authority designated for the programme(s) do not comply with
the designation criteria relating to internal control environment, risk management,
management and control activities and monitoring set out in Annex XX of the CPR.
This adverse opinion is based on………………...6
[The audit authority may also include emphasis of subject-matter, not affecting their opinion,
as established by internationally accepted auditing standards.]
Date
Signature
4 Indicate the authority(ies) and the designation criteria with which they do not comply.
5 Indicate the reason(s) for the reservation(s) entered for each authority and on each aspect.
6 Indicate the reason(s) for the adverse opinion for each authority and on each aspect.
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Annex 2B. Model audit report on the designation under Article 113bis(2) of the CPR
Content of the report
I. Introduction
a) Identify the objective of the report i.e. to set out the results of the assessment of the
compliance of the managing authority and the certifying authority with the
designation criteria relating to internal control environment, risk management,
management and control activities and monitoring set out in Annex XX of the CPR,
in order to express an opinion on their designation;
b) Identify the scope of the report i.e. the body(ies) covered, namely the managing
authority and the certifying authority and their compliance with the designation
criteria relating to internal control environment, risk management, management and
control activities and monitoring set out in Annex XX of the CPR, with reference to
the particular Funds and programmes covered;
c) Indicate the body that has prepared the report ("Independent Audit body") and
specify if it is the audit authority for the operational programme(s) covered;
d) Indicate how the functional independence of the Independent Audit body from the
managing and certifying authorities is ensured (Article 113bis(2) of the CPR).
II. Methodology and scope of the work
a) Indicate the period and timeframe for examination; (date when the formal systems
description was received by the Independent Audit body, date when the examination
started and ended and resources allocated);
b) Specify the extent of the use of previous audit work (2007-2013 programming
period) where applicable, in accordance with Article 113bis(2) of the CPR.
c) Specify a) the extent of the use of audit work carried out by other bodies and b) the
quality control performed on such audit work with respect to adequacy of work.
d) Describe the work done for the examination of the system description (Article 62 of
the CPR);
e) Describe the work done for the interviews with the staff in the main bodies; describe
the method and criteria for selection, what subjects have been covered, how many
interviews have taken place and who has been interviewed;
f) Describe the work done for the examination of other relevant documents concerning
the system; indicate any review of laws, ministerial acts, circulars, internal
procedure/other manuals, guidelines and/or checklists.
g) Describe the work done for the examination of the computerised systems for
keeping accounting records, for the storage and transmission of financial data and
data indicators, for monitoring and for financial reporting;
h) Indicate if any contradictory procedures have taken place prior to issuing this report
and indicate relevant authorities/bodies;
Confirm that the work has been carried out taking account of internationally
accepted audit standards (Article 113bis(2))
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i) Identify if there were any limitations on scope7.
j) Where functions have been delegated by the managing authority or the certifying
authority to other bodies, describe the work done to ensure that the managing and/or
certifying authority have assessed the capacities of these bodies to carry out
delegated tasks and have sufficient supervisory procedures in place over these
intermediate bodies.
III. Results of assessment for each authority/body /system
a) For each authority/body/system complete the table:
CCI
Number
Authority/
Body (Name
and Type
(MA, CA)
Completeness
and accuracy
of description
(Y/N)
Conclusion
(Unqualified,
Qualified,
Adverse) Shortcomings
Priority
axes
affected
Designation
criteria
affected
Recommendations
/ Corrective
measures
b) Provide results of the assessment of other specific areas if not fully covered under
(a), including an assessment of:
the procedures in place for drawing up the accounts referred to in article 59(5)
of the Financial Regulation (Article 115(b) of the CPR)
the arrangements for certifying the completeness, accuracy and veracity of the
accounts and that the expenditure entered in the accounts complies with
applicable Union and national rules (Article 115(c) of the CPR)
the procedures in place for ensuring an effective and proportionate anti-fraud
measures taking account of the risks identified. (Article 114(4)(c) of the CPR)
the arrangements for drawing up the management declaration and annual
summary of final audits and controls and weaknesses identified.
IV. Overall conclusion
a) Provide an overall conclusion with respect to compliance of the managing
authority (and the certifying authority) with the designation criteria relating to
internal control environment, risk management, management and control
activities and monitoring set out in Annex XX of the CPR ;
b) In case of reservation or qualification to the opinion, indicate the priority axis
or axes concerned;
7 Limitation on scope—A limitation on the scope of the auditor’s work may sometimes be imposed by the entity
(for example, when the terms of the engagement specify that the auditor will not carry out an audit procedure
that the auditor believes is necessary). A scope limitation may be imposed by circumstances. It may also arise
when, in the opinion of the auditor, the entity’s accounting records are inadequate or when the auditor is unable
to carry out an audit procedure believed desirable. [IFAC Handbook] ]
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