Archiving project documents means the obligation to keep the complete documentation relating to the preparation, implementation, settlement and audit of a project funded from EU funds. In practice, the beneficiary should keep not only the grant agreement and invoices, but also documents confirming the selection of contractors, the eligibility of expenditure, the completion of the material scope, the conduct of promotional activities, correspondence with the institution and documentation of project durability.
In the 2021-2027 perspective, the basic rule arising from Article 82 of Regulation 2021/1060 is that supporting documents relating to an operation must be kept for 5 years from 31 December of the year in which the managing authority made the last payment to the beneficiary, unless specific programme rules, State aid, audit proceedings or tax legislation require a longer period.
Why is archiving project documents so important?
Archiving project documents is not merely a formality after the project has ended. It is part of the system for controlling public funds. The funding institution, an auditor, the fiscal control authority, the audit authority or the European Commission may request documents confirming that the project was implemented in accordance with the agreement, the call rules, the budget, the schedule and the rules on the eligibility of expenditure.
A missing document may have consequences similar to an actual breach of the project implementation rules. If the beneficiary is unable to prove that an expense was incurred, that a contractor was properly selected or that an indicator was achieved, the institution may question the cost, impose a financial correction or demand the return of part of the funding.
In practice, archiving should be planned as early as the grant application stage. The more complex the project, the more important an orderly document storage system becomes. This applies in particular to investment projects, projects involving procurement, projects with State aid, projects settled in several tranches and undertakings requiring durability to be maintained.
How long must project documents be kept?
The basic retention period for documents in projects financed from European funds should always be verified in three places:
- in the grant agreement
- in the project selection rules
- in the legislation applicable to the given fund, programme and type of aid
For projects implemented in the 2021-2027 perspective, the starting point is the 5-year rule arising from Regulation 2021/1060. This period is counted from 31 December of the year in which the managing authority made the last payment to the beneficiary. This means that it is not automatically counted from the date of signing the agreement, from the date of physical completion of the project or from the date of the last invoice. What matters is the date of the last payment or a specific date indicated in the grant agreement.
Practical example: if the last payment to the beneficiary was made in 2027, the documentation must, as a rule, be kept at least until 31 December 2032. However, if the grant agreement or the programme documentation provides for a longer period, the longer period applies.
It should also be borne in mind that the retention period may be interrupted in the event of legal proceedings or at the request of the European Commission. In such a situation, documents should not be destroyed merely because the originally calculated archiving period has expired.
Archiving and project durability – not always the same period
A common mistake made by beneficiaries is to equate the document archiving period with the project durability period. These are two different obligations.
Project durability means the obligation to maintain certain project results, for example the fixed assets purchased, the places of implementation, the function of the investment, ownership of the infrastructure or the project results, for the period specified in the agreement and the programme rules.
Archiving project documents on the other hand, means the obligation to keep documents confirming the correct implementation, settlement and maintenance of the project.
In practice, the durability period may be 3 or 5 years, but documents may have to be kept longer because the archiving period is counted from a different point in time. The beneficiary should therefore not destroy documentation merely because the project durability period has ended.
Which project documents must be kept?
The scope of archiving should cover all documentation that can confirm the correctness of project implementation. Keeping only invoices and the agreement is not enough. An audit usually examines the entire decision-making trail: from the application, through the selection of the contractor, delivery of the goods or service, payment and settlement, to the durability of results.
Documents relating to project preparation
The archive should include documents showing the basis on which the project was prepared and approved.
- the grant application together with the final version of the budget
- the business plan, feasibility study, financial model or economic analysis, if required
- annexes to the application
- the applicant’s registration and formal documents
- documents confirming SME status, if relevant to the call
- declarations made at the application stage
- correspondence with the institution before signing the agreement
- documents confirming the eligibility of the project and the applicant
Grant agreement and programme documents
The beneficiary should keep the complete set of documents setting out the conditions for implementing the project.
- the grant agreement or funding decision
- all annexes to the agreement
- the current physical and financial schedule
- approved changes to the project
- the project selection rules
- guidelines and instructions applicable to the project
- letters, consents and decisions of the institution
- confirmations of correspondence conducted via CST2021, ePUAP, e-Delivery or e-mail
It is also worth keeping the versions of documents in force on the date of submitting the application and signing the agreement. During the multi-year implementation of a programme, rules and instructions may be updated, so for audit purposes it is important to establish which rules applied to the beneficiary at a given moment.
Financial and accounting documents in the project
Financial documentation is one of the most frequently audited areas. It should make it possible to link each expense unambiguously to the project, the budget, the payment and the material scope.
The archive should include in particular:
- invoices, bills and other accounting documents
- proof of payment
- bank statements
- documents recording the expenditure in the accounts
- the project’s accounting records or printouts from analytical accounts
- accounting notes, invoice corrections and explanations
- documents confirming the absence of double financing
- VAT documents, where VAT was an eligible or ineligible cost
- payrolls, bills under civil-law contracts and declarations, if the project included staff costs
- depreciation documents, if depreciation was claimed
- documents relating to the own contribution
For accounting documents, accounting and tax legislation must also be taken into account. The Accounting Act provides for separate retention periods for accounting books, accounting vouchers and other documents, and the Tax Ordinance links the obligation to keep books and documents to the limitation period for the tax liability.
The practical rule is simple: if several retention periods apply to the same document, the longest of them should be applied.
Documents relating to procurement and the selection of contractors
Procurement documentation is one of the most important elements of the project archive. This applies both to procedures conducted under the Public Procurement Law and to purchases made in accordance with the competitiveness principle, a market survey or an internal purchasing procedure.
Depending on the contract value and the programme rules, the following should be kept:
- documents estimating the contract value
- market survey notes
- requests for quotation
- confirmations of the publication of requests
- contractors’ offers
- questions from and answers given to contractors
- contractor selection reports
- justification for the choice of offer
- documents confirming the absence of a conflict of interest
- contracts with contractors
- annexes to contracts
- acceptance reports
- documents confirming the completion of the supply, service or construction works
- correspondence with contractors
The archive should not be limited to the invoice and the acceptance report alone. An audit may examine whether the expenditure was incurred in a competitive, transparent and rational manner consistent with the project budget.
Documents confirming project implementation
The beneficiary should keep evidence that the project was actually implemented in accordance with the application and the agreement.
Depending on the type of project, these may include:
- acceptance reports
- photographic documentation
- technical documentation
- permits, notifications and administrative decisions
- certificates, approvals and instructions
- warranty cards
- serial numbers of the equipment purchased
- the fixed asset register
- OT documents (fixed asset commissioning)
- test or system commissioning reports
- documents confirming that the indicators have been achieved
- documents confirming the use of the assets purchased
In investment projects, it is particularly important to retain evidence that the devices, equipment or software purchased are used in accordance with the project objective. The purchase alone is not always sufficient to demonstrate correct implementation.
Documents relating to project promotion
In projects financed from EU funds, the beneficiary usually has information and promotion obligations. Their scope depends on the programme, the value of the project and the type of support.
It is worth keeping the following in the archive:
- photographs of information boards, posters or stickers
- screenshots of the website
- screenshots from social media
- copies of promotional materials
- documents confirming the labelling of the equipment purchased
- correspondence concerning promotional obligations
- documents confirming the correct use of logos and funding information
Can documents be stored electronically?
Project documents may be in paper or electronic form, but what matters most is their completeness, authenticity, legibility and accessibility for audit purposes.
If a document was created electronically, you should not rely solely on a printout. This applies in particular to documents signed with a qualified electronic signature, documents with a trusted signature, correspondence from ICT systems, dispatch confirmations, UPO (official acknowledgements of receipt) and documents submitted via CST2021.
A good electronic archive should include:
- the original source files
- electronic signature files, if they are separate
- dispatch and receipt confirmations
- the versions of documents submitted to the institution
- a logical folder structure
- document register
- restricted access to documents containing personal data or confidential information
In practice, it is worth applying a simple rule: a document must be possible to find, open, verify and link to a specific expense or project activity even several years after the project has ended.
How to organise the project archive?
It is best to build the archive according to the logic of a project audit, not just by date. Auditors usually expect to be able to trace the entire history of a given expense or activity quickly.
An example archive structure may look as follows:
01_Application_and_agreement02_Annexes_and_changes03_Budget_and_schedule04_Procurement_and_contractors05_Invoices_and_payments06_Accounting_and_VAT07_Acceptance_and_physical_implementation08_Indicators_and_results09_Project_promotion10_Correspondence_with_institution11_Audits_and_explanations12_Project_durability13_State_aid_and_de_minimis
For larger projects, it is worth keeping a document register. Such a register may include the name of the document, the date, the expense number, the cost category, the file location, the form of the document and information on whether the document was submitted to the institution.
The most common mistakes in archiving project documents
The most common problems do not result from a complete absence of documents, but from the lack of a complete evidence trail. The beneficiary has an invoice, but no estimate of the contract value. They have a contract with the contractor, but no offers. They have an acceptance report, but no evidence that the equipment was actually put into operation. They have e-mail correspondence, but have not kept the attachments.
The most common mistakes are:
- keeping only invoices and the grant agreement
- no documents relating to the selection of the contractor
- no payment confirmations
- no versions of electronically signed documents
- no documents confirming the achievement of indicators
- no photographic documentation
- no archiving of correspondence with the institution
- documents not organised by expense
- deleting documents after the end of project durability
- keeping documents on a single computer only
- no procedure for accessing documents after a change of staff or accountants
Document archiving and project audits
An audit may take place during project implementation, when a payment claim is approved, after the project has ended or during the durability period. It may take the form of a document audit, an on-site inspection, a cross-check or an audit.
During an audit, the beneficiary should be able to present documents in an orderly and coherent manner. The key is being able to demonstrate:
- who made the decision on the expense
- why the expense was needed
- whether the expense was consistent with the budget
- how the contractor was selected
- whether the purchase was actually made
- when the payment was made
- where the equipment or infrastructure purchased is located
- whether the project achieved the planned indicators
- whether the information and promotion obligations were met
- whether project durability was maintained
A well-prepared archive shortens the duration of an audit and reduces the risk of having to assemble documents chaotically only after receiving a request from the institution.
When is it worth using the support of an advisor?
Advisory support is particularly useful when a project involves many cost categories, procurement, changes to the material scope, State aid, staff costs, several locations or complex VAT settlement. In such cases, the archiving of project documents should be linked to ongoing project management and audit preparation.
On the dotacje-online.pl website, you can use the grant advisory services, covering the analysis of documentation, preparation of applications, support in project settlement and the assessment of formal and financial risks. If the project is already under way, it is worth organising the archive before submitting the final payment claim.
If you are planning to apply for funding or are already implementing a project, it is worth planning in advance not only the preparation of the application, but also how you will document expenditure, select contractors and later archive the documentation.Contact us
Author: Dariusz Kozakiewicz
EU funding expert