UKRO regularly receives questions about financial audits and technical reviews on lump sum projects. We put together this summary to help applicants to lump sum calls and participants in active lump sum projects understand the audit requirements better.
This summary refers to official European Commission (EC) guidance documents, FAQs and events where answers to questions about audits, checks and reviews on lump sum projects have been answered.
Questions
Are the rules for checks, reviews, audits and investigations of lump sum grants the same as for actual cost grants?
“The rules for checks, reviews, audits and investigations of lump sum grants are the same as for actual cost grants, as far as horizontal obligations and technical project implementation is concerned.
As there is no financial reporting, there are no financial checks, reviews or audits related to actual costs and the resources used.
Controls can focus on the proper implementation of the work plan (of the activities) and on nonfinancial obligations. This includes compliance with rules on intellectual property, ethics and integrity, visibility of EU funding, etc.”
‘How to manage your lump sum grant’ (p.13)
Are there financial checks or audits for Horizon Europe or Horizon 2020 lump sum grants?
“There are no financial checks, reviews, or audits to check costs because there is no obligation to document the costs incurred for the action. Obligations to keep financial records outside the grant agreement still apply (e.g. under internal procedures or under national law).
Checks, reviews, and audits can focus on the proper implementation of the action and on any non-financial obligation, such as the promotion of the action, the visibility of EU funding, ethics and research integrity, dissemination and exploitation of results, management of intellectual property, obligations related to open science, etc.”
In case my lump sum grant is audited, do I need to provide complete accounts or individual salary statements?
“Under the lump sum grant agreement, there is no obligation to keep records on the actual costs incurred. However, you may have to comply with other record keeping requirements outside the lump sum grant agreement (e.g., under national law or your internal procedures). It is possible that some of these records, if relevant for the project, are used in case of an audit to verify the reality of the work done. This includes the points mentioned in Article 25.1.3 (i.e., complete accounts, individual salary statements or other personal data). Such information and data can also be requested in the specific context of certain investigations, for example, related to fraud suspicion.”
Which documents must be kept and presented in case of checks, reviews, audits or investigations of Horizon Europe or Horizon 2020 lump sum grants?
“Beneficiaries must keep adequate records and other supporting documentation to prove the proper implementation of the action for at least 5 years after the balance is paid (3 years for grants up to EUR 60 000). Those records must be available, verifiable, and auditable. For lump projects, beneficiaries do not need to keep records of their actual costs (e.g. timesheets or invoices). There is no financial reporting, and no checks or audits of the costs incurred. It goes without saying that participants still have to comply with financial record keeping obligations outside the grant agreement (e.g. under national law or under internal procedures).
In case of checks, reviews, audits or investigations, the beneficiaries of lump sum grants must present adequate records and other supporting documentation to prove the proper scientific and technical implementation of the action, as detailed in Annex 1 (e.g. for research activities, documentation required by good research practices such as lab books, technical documents, prototypes, publications, proceedings in conferences, etc.) The scientific and technical documentation required for lump sum grants is the same as for all grants (i.e. there are no additional technical documents to be kept specifically for lump sum grants).”
What detailed checks are envisaged on lump sum projects under Horizon Europe?
“For some programmes (e.g. HE), additional, in-depth ex-post technical reviews are foreseen to verify the proper implementation of the completed work packages in lump sum grants. Like standard project reviews, ex-post technical reviews are done with external experts and concern the technical implementation of the action (see AGA — Annotated Grant Agreement, art. 25*).
Ex-post technical reviews have the following specific features:
- They take place ex-post, after an interim/final payment, and are launched up to 2/3/5 years after the payment of the balance (see the standard time-limits after project end in the grant agreement; Data Sheet, Point 6).
- They focus on the work of a single participant, for which lump sum contributions were paid at the end of a given reporting period.
- They routinely analyse supporting documents that prove proper implementation (see section 8), in addition to the project reports.
- If needed, they may include interviews with participant contacts and, if applicable, key staff involved in the project, e.g. researchers.
- If needed, they may include on-site visits to cover aspects that cannot be verified remotely.”
‘How to manage your lump sum grant’ (p.13)
Do applicants need to include the cost of an audit certificate (Certificate on the Financial Statements) in their lump sum project budget?
“Certificates on the financial statements are not used in lump sum grants.”
‘How to manage your lump sum grant’ (p.10)
Consequently, the cost of an audit certificate is not eligible on lump sum project and should not be included in the project budget as confirmed during this EC webinar [time stamp 1:27:04]
What records do applicants need to keep for audits by other EU bodies such as OLAF (European Anti-Fraud Office) or the European Court of Auditors?
While certain EU bodies retain the right to audit any EU expenditure (incl. lump sum projects), the beneficiaries are not required to retain any financial records for specific lump sum projects as explained during the following EC webinars:
- Lump Sum Funding in Horizon Europe: How does it work? How to write a proposal? (23 October 2024) [time stamp 1:06:27]
- Lump Sum Funding in Horizon Europe: Quick overview of the main features (18 June 2025) [time stamp 37:00]
What are the record-keeping requirements on lump sum projects?
“You have no contractual obligation to keep financial records for the project. There is no reporting of actual costs or of resources. You will only need to comply with record keeping and other legal obligations outside the lump sum grant agreement, if any (e.g. under national law or internal procedures).
You must keep documentation to demonstrate that the activities in Annex 1 have been carried out, and by whom. This is the same technical documentation as for all grants (i.e. there is no additional technical documentation to be kept specifically for lump sum grants; see AGA — Annotated Grant Agreement, art. 20*). For example, for research activities, you should keep documentation as required by good research practices such as lab books, technical documents, prototypes, proceedings in conferences, and publications.”
‘How to manage your lump sum grant’ (p.13-14)