6.2 Project changes

EUI-IA projects must be implemented according to the approved Application Form. The Initiation Phase (see Chapter 4.2 “Project readiness check (including ex-ante audit)” for more details) is designed in a way to optimise projects’ prospects to be implemented on time and as planned. However, projects may encounter the need to modify certain elements related to implementation to adapt to new developments or circumstances. This should be authorised provided that projects’ objectives and its key characteristics, notably in terms of innovation – with the inherent risk to fail – are preserved. EUI-Innovative Actions has a set of standardised rules and conditions under which approved projects can request modifications during their implementation.

Three main categories of changes are recognised:

Minor changes are mere adjustments to the project set-up, having no or very limited impact on the achievement of project objectives or the overall project implementation. They do not require any formal request for change; they only need to be communicated to the Permanent Secretariat.

Technical adjustments are related to the changes in the budget, Partnership and length of the EUI-IA project having no or very limited impact on the achievement of project objectives or the overall project implementation. They require a formal Request for Change which needs to be approved by the Permanent Secretariat. Technical adjustments must be reflected in the Application Form which can be edited only once the Request for Change is approved and a formal communication is sent by the Permanent Secretariat.

Major changes are relating to substantial elements of the project, having a more significant impact on its implementation. Major changes are to be considered as exceptional, may be approved only in duly justified cases and cannot affect the core scope of the project and its innovativeness. They require a formal Request for Change to be submitted to the Permanent Secretariat and approved by the Entrusted Entity. All major changes must be reflected in the Application Form which can be edited only once the Request for Change is approved and a formal communication is sent by the Permanent Secretariat.

They may consist of:

• Changes in contact and bank details. The contact details of the management team and the bank account is directly updated by the MUA in the EEP without prior approval from the Permanent Secretariat. It should be noted that bank details cannot be modified during the period between the verification of the FLC and the ERDF payment to the project by the Accounting Authority.
• Changes in a Partner VAT status, type, representative, legal status or name (following a merger for instance). These changes should be communicated to the Permanent Secretariat and a signed letter provided confirming the change with a declaration that the new legal entity assumes all responsibilities of the previous legal entity as described in the Application Form and there is no change in responsibilities, activities, role and budget. They may lead to an update of the approved Application Form or amendment of the Partnership Agreement.
• Minor changes in the Work Plan and budget that have a very limited impact on project implementation, such as:
  • minor changes to deliverables (definition, target value, delivery date);
  • minor changes to the project implementation timeline (rescheduling of activities);
  • location of events;
  • changes in the communication tools;
  • budget changes within the flexibility rules[1];
  • minor changes to Result Indicators (clarification of definition, target values, introduction of new indicators).

Minor changes in the Work Plan and budget should be duly justified and reported to the Permanent Secretariat through the Annual Progress Report. The Permanent Secretariat will revise and, if duly justified, approve the changes proposed. Please note that some of them might be assessed by the Permanent Secretariat as underachievement and requested to be reported as such. It is not necessary to update the Application Form in case of minor changes.

There are three types of technical adjustments – below are presented the conditions under which they can be requested. The approval body is the Permanent Secretariat on behalf of the Entrusted Entity.

• Changes in the budget. Changes in budget exceeding the flexibility rules[2] are considered as a technical adjustment when the content of the project is not affected and are allowed in duly justified cases. It should be noted that no additional ERDF can be asked for.
• Changes in the Project Partnership. Changes in Partnership may concern the withdrawal or the integration of new Project Partner(s). Being a core element, changes to the composition of the Partnership should be limited as much as possible. The formal request shall describe the new allocation of activities and budget, particularly:
  • Partner withdrawal: it shall be demonstrated that the remaining Partners undertake rapid and efficient solutions to ensure the further implementation of the project. The responsibilities and project tasks of this withdrawn Delivery Partner must be reallocated within the existing Partnership (or taken over by a new Delivery Partner).
  • Inclusion of an additional Partner: the added value for the project implementation must be clearly demonstrated and justified. The budget of the new Delivery Partner must come from the approved project budget. A new Partner cannot lead to any increase of the overall and ERDF project budget.
• Changes in project duration. Projects are expected to complete their activities successfully within the time laid out in the Application Form. They are requested to inform the Permanent Secretariat in case of difficulties that may lead to delays in the delivery of activities. The extension of a project duration is limited to well justified cases whilst still allowing a proper project evaluation and cannot exceed 6 months. In any case, the total project implementation period is maximum 4 years (extension included) and cannot be exceeded in any case.

Major changes can be requested only in exceptional cases, if properly justified by circumstances and if other means of solving the implementation problems are exhausted. Requests will be carefully assessed in order to determine their impact on the project objectives, the innovative character of the experimentation and the overall prospects on project implementation. Request for Change will be rejected if it seriously undermines the value of the original project (please see below for more details). The approval body is the Entrusted Entity.

Major changes relate to:

• Changes in the content. Changes in content concern modifications having a major and substantial impact on the Work Plan: Work Packages, investment elements, activities, outputs, main deliverables or Result Indicators. They will not be allowed if they substantially alter the planned nature of the project, its quality, or its ability to deliver the key component(s) of the innovative solution or to reach the initial objectives and results.

The latest approved version of the Application Form constitutes the basis on which to assess a project changes.

• The MUA is invited to contact the Permanent Secretariat as soon as a potential modification is identified to discuss the possibilities and options for changes.
• During their Implementation phase, approved projects can submit maximum 2 Requests for Change leading to a technical adjustment or to a major change.
• After their Implementation phase, approved projects can request 1 final budget technical adjustment. These can be requested up to the submission of the FC2 to the FLC, provided they are limited to mere technical budgetary changes (i.e. to adjust the budget forecasts to the reality of the spending) and not linked to any substantial changes to project activities (i.e. changes in the Partnership or content).
• Each Request for Change can include several categories of changes.
• No Request for Change should be submitted later than 2 months before the end of the implementation of the Work Packages being subject to change, except for the above-mentioned budget adjustments prior the FC2 submission.
• Technical adjustments and major changes require prior approval (of the Permanent Secretariat or Entrusted Entity).
• The MUA is responsible for requesting any change on behalf of the Project Partnership and the Permanent Secretariat is its sole interlocutor.
• ERDF increase is not allowed in a Request for Change.

The assessment of the Request for Changes may result in one of the following outcomes:

• Approval of the Request for Change: the change will only enter into force after the approval from the relevant EUI Authority has been received. However, once approved they are valid retrospectively starting from the date when the written request was submitted to the Permanent Secretariat. All (and only) approved changes must be reflected in the updated version of the Application Form. When required, an amendment to the Partnership Agreement will be requested.
• Insufficient and/or unclear information to carry out an assessment: during the assessment phase, the Permanent Secretariat may ask for relevant clarifications to the MUA.
• Rejection of the changes requested: the project will continue to be implemented on the basis of the last approved version of the Application Form. It is to be noted that expenditures related to activities or Project Partners which have not (yet) been approved are not eligible. In extreme cases, if the Entrusted Entity establishes a change seriously undermines the value of the original project and all means of solving implementation problems have been exhausted (i.e. in case of partial or more complete failure of the experimentation/in delivering the project), it will decide to end support to the project and terminate the Subsidy Contract.

Please note that whenever the MUA has doubts regarding proper classification of the nature of the foreseen project changes (minor versus technical and major requiring submitting a formal Request for Change) it is recommended to contact the Permanent Secretariat in advance for clarification and advice.

Please see the figure below (Figure 9) for the overview of the presented above information.

Figure 9. Project changes

Please note that, during the Initiation Phase, the follow-up on Selection Committee recommendations, ex-ante audit or project readiness check findings, required Result Indicators corrections, etc. may lead to adjustments in the Application Form, at the initiative of the Entrusted Entity only when judged necessary for the signature of the Subsidy Contract.