Strengthening the CER framework

Since this message does not prevent you from submitting the proposal you can go on with the submission.

A beneficiary of the project can invite persons from other entities to participate in project activities (if this is justified and needed for the specific activity) without the need to have those entities as an “affiliated entity” or an “associated partner” in the proposal. Do note that if an organization joins as associated partner it would be required to carry out the activities as it foreseen to carry out in the proposal, without being eligible for EU co-financing. Therefore, staff cost as well as their travel, accommodation and subsistence of an associated partner taking part in the action cannot be reimbursed.

Applications can only be submitted by a consortium. For topic ISF-2026-TF2-AG-CER-TEST the proposal should have at least 4 applicants (beneficiaries; not affiliated entities) from 2 different EU Member States, Norway, Iceland or Liechtenstein, at least one of which is established in an EU Member State. .For topic ISF-2026-TF2-AG-CER-STRENGTH: the proposal should have at least 3 applicants (beneficiaries; not affiliated entities) from 2 different EU Member States, Norway, Iceland, Liechtenstein, European third countries, at least one of which is established in an EU Member State. See also page 12 of the call document

Under the first topic the following applicants (beneficiaries and affiliated entities) are eligible to participate:

• Legal entities (public or private bodies, non profit organizations etc.)
• Be established in one of the eligible countries

Please refer to page 14-15 of the Call for the specific requirements.

Applicants are not requested to have been formally identified as a critical entity by the competent national authority.

As regards the ISF-2026-TF2-AG-CER-STRENGTH only specific European third countries (not member of the European Union), namely Norway, Liechtenstein and Iceland, can participate without limitation (following of course the requirements concerning the composition of the consortium).

Third European countries are considered those participating in the European Neighbourhood Policy (ENP) (Ukraine, Moldova, Georgia, Armenia, Azerbaijan, Belarus) and candidate countries (Turkey, Albania, Bosnia and Herzegovina, Montenegro, Serbia, North Macedonia, Ukraine and, Moldova, Georgia, and Kosovo). UK and Switzerland are also eligible.

Please do note that given the current political situation in Georgia and the nature of this call, its participation is not foreseen. Please also note that EU relations with Belarus are currently frozen at the state level, therefore its participation is also not foreseen.

However, as regards other European third countries their participation should be clearly justified, for example in relation to cross-border risk assessment activities and cross-border interdependencies of the provision of essential services.

Please refer to page 14-15 of the Call where the requirements for the applicants are defined and also to page 17 concerning the consortium composition. There is no reference to minimum or maximum number of a specific category of partners. However, 2 research partners is not a valid number of applicants for the Call as the minimum number of applicants for topic ISF-2026-TF2-AG-CER-TEST are least 4 applicants (beneficiaries; not affiliated entities) and for topic ISF-2026-TF2-AG-CER-STRENGTH, the minimum number is at least 3 applicants (beneficiaries; not affiliated entities).

For the period 2021-2027 the HOME Funds (AMIF, BMVI and ISF) apply the unit costs for travel, accommodation and subsistence (as specified by the Model Grant AgreementPDFand Annotated Grant AgreementPDF).

The use of the unit costs should be seen as a simplification and cutting red tape. Specific rationale for applying the unit costs can be found in the Commission Decision C(2021)35PDF that was amended by Commission Decision C(2023)4928 finalPDF. Decision specifies in which cases the unit costs are mandatory to be applied – in general all travels above 400km independent of the direction as well as in the range 50-400km within and between the Member States. For directions not covered by the decision (e.g. travel between 50 and 300km in a third country; travel between 50 and 300km and between a Member State and a third country, and; land travel between 50 and 300km in Luxembourg, Cyprus or Malta), actual costs of travel, accommodation and subsistence, also in line with the local accounting and tax rules are to be used. For specific rules, please refer to section ‘General > Article 6.2.C.1 Travel and subsistence’ of the Annotated Grant AgreementPDF.

In practice, it is advised to use the unit costs as reference while establishing your draft budget at proposal stage.

During the implementation of the project you will incur costs according to your usual practices but you will have to declare your travel, accommodation and subsistence, in your final payment request, as unit costs in accordance with the article 6.2.C.1 of the model grant agreement.

FULL QUESTION: I wanted to confirm that in the budget in the second to last column (Own resources/EUR) I should indicate own contribution, which for this call is 10%. Therefore, in the last column (Total estimated project income/EUR) I will have the sum of requested grant amount and own contribution (100% of project budget).

REPLY: Your understanding is correct.

Eligible costs are costs incurred by a beneficiary, against an invoice (or similar). Loss of revenue is not a cost.

Please, refer to the Grant Agreement (general-mga_amif-isf-bmvi_en.pdfPDF) for an explanation of eligible costs.

No, there is no specific minimum or maximum. But do take into account the ‘whereas (20)’ of the ISF regulation where it reads that the Fund should support investments in equipment, means of transport and facilities only where such investments have clear Union added value, and only to the extent that those investments are necessary to achieve the objectives of the Fund. For example, such investments could include investments in equipment needed for forensics, covert surveillance, explosives and drug detection and any other specialised purpose within the objectives of the Fund. The Fund should not finance investments of purely national relevance or investments that would be necessary for the everyday work of the competent authorities, such as uniforms, cars, buses, scooters, police stations, non-specialised training centres and office equipment

The eligibility of a cost is determined at the end of the project at the submission of the final report. In order to be eligible costs need to comply with the general eligibility conditions mentioned in article 6.1, namely that :

they must be actually incurred by the beneficiary

they must be incurred in the period set out in Article 4 (with the exception of costs relating to the submission of the final periodic report, which may be incurred afterwards; see Article 21)

they must be declared under one of the budget categories set out in Article 6.2 and Annex 2

they must be incurred in connection with the action as described in Annex 1 and necessary for its implementation

they must be identifiable and verifiable, in particular recorded in the beneficiary’s accounts in accordance with the accounting standards applicable in the country where the beneficiary is established and with the beneficiary’s usual cost accounting practices

they must comply with the applicable national law on taxes, labour and social security and

they must be reasonable, justified and must comply with the principle of sound financial management, in particular regarding economy and efficiency

and the specific conditions mentioned in article 6.2 of the grant agreement

The list of the previous projects as a separate mandatory annex is mentioned in point 5 of the call text.

As mentioned in point 11 of the Call for proposals document, applicants shall submit their proposal via the Electronic Submission System of the Funding & Tenders Portal (SEP). There, applicants can find a document entitled “Part B template”. They shall download this document and cut from it the content of its last page, entitled a “List of previous projects” including a dedicated table. That list shall be duly filled in by the applicant, saved as a separate document, and then uploaded (in PDF format) in the dedicated space in the Funding & Tenders Portal Electronic Submission System.

That way we ensure that only part B, related to the description of action, is subject to the control of the maximum page-limit set in the call text.

In the interest of equal treatment of applicants, the Commission cannot give a prior opinion on the eligibility of applicants or actions , please see the objectives of this part of the call, i.e. "projects will support the fulfilment of the objectives of the CER Directive by facilitating cooperation as regards resilience of critical entities and of critical infrastructure in the EU (…) and support the effective implementation of the CER Directive by Member States and by critical entities".

Also see the eligibility conditions in terms of the minimum number of entities (3) and minimum number of Member States (2).

The Call for Proposals is provided only in English.

By selecting the language of your choice in the EU Funding and Tenders Portal you may get a machine translation of the documents. However, the content not available in your chosen language will be presented only in English.

The CFS is required if the requested EU contribution to costs is ≥ EUR 100 000 per beneficiary

All equipment purchased either using the full cost principle or via depreciation needs to be used and purchased exclusively for the action. As stated in the call document (footnote 33) If the equipment is a direct cost, then the general rule is the depreciation cost, i.e. the Commission only pays for the use during the lifetime of the project. However, in some specific cases, the Commission derogates from the general rule and envisages in the call text to reimburse the full purchase price. It can be the case that buying equipment is essential for the project or even is the main purpose of the project: for example, when the project aims as setting up investigation facilities, or at building capacities. If the project is awarded, the list of equipment will be copied into the grant agreement, and only the equipment actually listed in the grant agreement will be eligible (every change of this list will imply an amendment of the grant agreement. In your application you would need to justify the purchase of equipment at full cost.

The AGA reads on this (page 96): Purchases of equipment, infrastructure or other assets used for the action must be declared as depreciation costs, calculated on the basis of the costs actually incurred and written off in accordance with international accounting standards and the beneficiary’s usual accounting practices.

Only the portion of the costs that corresponds to the rate of actual use for the action during the action duration can be taken into account.

Do note that if the beneficiary’s usual practice is to consider durable equipment costs (or some of them) as indirect costs, these can NOT be declared as direct costs, but are covered by the flat rate for indirect costs (see Article 6.2.E). Any depreciation declared as a direct cost under the action must be a direct cost under the beneficiary’s cost accounting practices (see Article 6.2).

The costs must comply with the eligibility conditions set out in Article 6.2.C.2