VIZSG/28/2023 – GINOP Beneficiary change system review – summary

The Beneficiary change system review examined contract modifications concerning self-initiated project transfers¹, based on a sample of GINOP projects from the 2014–2020 period affected by beneficiary changes, as provided to the Authority.

The system review, conducted on a selection of 73 projects affected by self-initiated project transfers, concluded that the option of self-initiated project transfer within the application management system is fundamentally at odds with the high level of competition observed in the decision-preparation phase – whereas the presence of competition contributes to the high professional quality and economic soundness of the submitted grant applications. This is because in cases of self-initiated project transfer based on an agreement between economic operators, the decision regarding the selection of the new beneficiary is not made by the relevant managing authority, but rather by the original and the new beneficiary. Consequently, this opens up a pathway that increases the risk of abuse, allowing economic operators to gain access to funding even if they did not, or would not have been able to, meet the original conditions of the call for applications.

In its report, the Authority made recommendations, primarily in relation to the 2021–2027 programming period, regarding procedures governing contract modifications, internal regulations, as well as the assessment of contract modifications at identified oversight and control points, and the evaluation of the project to be implemented by the new beneficiary.

1 self-initiated project transfers are a category of contract modifications initiated by beneficiaries, whereby a project is transferred to another economic operator/business company based on the beneficiary’s own decision)