South Baltic invited to the High Level Group on Simplification

The buzzword of “simplification” is high on policy agendas across Europe. However, while everybody can agree to the general principle, the “devil often lies in the detail”. In 2015, a High Level Group of Independent Experts was thus set up to advise the European Commission with regard to simplification and reduction of administrative burden for the beneficiaries of European Structural and Investment Funds (ESIF).

On 21 June 2016, the South Baltic Programme was given the opportunity to contribute to the working session of the High Level Group (HLG) on “gold-plating”. “Gold-plating” refers to the overall complexity of the current regulatory framework for ESI Funds and the tendency to define administrative extra requirements and burden at national and sub-national levels. Putting the term of complexity into spotlight, the presentation of Thorsten Kohlisch, Head of South Baltic’s Joint Secretariat, gave emphasis to the challenge of state aid management and the need to simplify the existing set of state aid rules for the business of European Territorial Cooperation (ETC). Indeed, looking at South Baltic’s practical experience gained under the first call for proposals in early 2016, significant human and financial resources had to be allocated to the “art of managing state aid”. Furthermore, additional burdens and responsibilities will be put on the shoulders of beneficiaries in the course of project implementation.

Consequently, the South Baltic Programme used the possibility of the HLG meeting in Brussels to propose concrete actions for the simplification of state aid management in the current programming period. In particular, the suggestion to extend Article 20 of the General Block Exemption Regulation (GBER) towards an umbrella for Interreg was shared with the 12 members of the group. Considering Interreg’s minimal potential to distort the functioning of the European single market, such umbrella could cover all beneficiaries, sectors and co-financing rates of typical Interreg projects, thus bringing the principles of proportionality, legal certainty and efficiency to life for the beneficiaries of ETC. At the same time, more thorough state aid assessments could be required for larger-scale investment projects with direct economic impact.

Beyond the challenges related to state aid, the intervention of the South Baltic Programme pointed at the risk of “neutralising” the simplification efforts at management level through an increase of audit and control burdens. Again, the principle of proportionality should be kept in sight, taking into account Interreg’s moderate budget volume and favourable record of irregularities. Furthermore, open mindsets towards the use of simplified cost options (SCOs) need to be triggered in order to ensure their acceptance at all management and control levels. In fact, increased legal certainty could help Interreg programmes to fully exploit the menu of SCOs offered by the regulations, thus allowing funded partnerships to allocate more resources to their “real project work” on the ground.

Finally, South Baltic called upon decision-makers to take the specificities of Interreg into account when designing “one-size-fits-all” e-solutions for the administration of ESI Funds. Indeed, as the practical experience in different EU Member States has shown, the multi-activity and multi-partner character of Interreg can quickly increase the complexity of online databases and platforms, thus requiring the involvement of Interreg experts from the first day of tool development. Altogether, as stipulated in the HLG’s final report on “gold-plating”, the process of simplification should be driven by the principle of “common sense”, designed to achieve “real” simplification for programmes and beneficiaries in the fields of management and control (audits), state aid, rule-setting (primary and secondary regulations), public procurement, monitoring and evaluation.

The final report on “gold-plating” of the High Level Group on Simplification and the experts’ presentations can be found here:

Learn more about the work of the High Level Group and their members here:

Get engaged and share your ideas for simplification with the High Level Group here: