Formal deficiencies in an application – how to avoid them and not lose your chance of a grant

Formal deficiencies in a grant application are one of the most common reasons for projects being rejected even before the substantive assessment by experts. To avoid them, you should above all read the call rules carefully, draw up a checklist of required annexes, verify the consistency of the data in the application generator and allow a sufficient time margin before the call closes.

In practice, most deficiencies are technical in nature and can be eliminated, if the applicant consciously manages the documentation preparation process.

Below we present a detailed analysis of the most common formal deficiencies and specific procedures that help minimise the risk of a negative formal assessment of the application.

What are formal deficiencies in a grant application

Formal deficiencies are all shortcomings in the application documentation that concern the technical, formal or administrative requirements set out in the call rules, rather than the substantive content of the project itself. This category includes, among others, missing required annexes, an incorrect file format, inconsistent applicant identification data, missing proper signatures, exceeding character limits or submitting the application after the deadline.

It is worth distinguishing between two concepts that are sometimes confused. A formal deficiency concerns administrative requirements, whereas an obvious clerical error is a minor error that does not affect the substantive content of the document and can be corrected at the request of the institution.

In most programmes, the applicant is given the opportunity to remedy formal deficiencies within the deadline set by the institution – usually 7 to 14 days. Some deficiencies, however, cannot be remedied – their occurrence results in the application being rejected without the possibility of correction.

The most common formal deficiencies in practice

An analysis of requests for supplementary information sent by intermediate bodies makes it possible to identify several recurring categories of deficiencies.

• Annexes – applicants often forget to attach the business plan, the physical and financial schedule, de minimis aid declarations, registration documents, financial statements for the required period or confirmation of SME status.
• Applicant identification data – inconsistency of the NIP, REGON or KRS number or the registered office address with the information shown in public registers is one of the most frequently identified deficiencies. Institutions verify these data on the basis of publicly available databases such as the KRS register, CEIDG or the White List of VAT taxpayers.
• Electronic signatures – the application must be signed by a person authorised to represent the applicant in accordance with the rules of representation disclosed in the KRS or CEIDG. The type of signature (qualified, trusted or personal) must comply with the requirements of the rules. In the case of joint representation, the absence of the signature of one of the authorised persons means that the document is deemed unsigned.
• Consistency of financial data – discrepancies between the amounts in the physical and financial schedule, the project budget, the business plan and the main application are a typical reason for requests for supplementary information. Each amount of eligible costs must be identical in all application documents.

How to avoid formal deficiencies – a step-by-step procedure

Analysing the call rules before starting work

The first and key step is to read the call rules and all the annexes to the call documentation in detail. The rules set out the catalogue of required documents, the format in which they are to be submitted, the method of formal verification and the catalogue of remediable and irremediable deficiencies. Particular attention should be paid to the formal project selection criteria, as they form the basis of the first stage of assessment.

Practical recommendation: after reading the rules, it is worth drawing up your own checklist of formal requirements covering all the admissibility conditions for the applicant, the project and the expenditure. Up-to-date information on grant programmes is available in the grant search engine, where the basic parameters of the call can be verified.

Verifying the applicant's eligibility

Before starting to prepare the application, you must confirm that the entity meets all the applicant eligibility criteria of the given programme. This applies in particular to SME status in accordance with the definition contained in Annex I to Commission Regulation (EU) No 651/2014, PKD codes corresponding to the activity covered by the project, financial history, no arrears in public-law liabilities and the absence of any exclusion circumstances.

Drawing up a list of annexes

Each programme and each call has its own catalogue of required annexes. As standard, it includes:

• registration documents,
• financial statements,
• State aid and de minimis aid declarations,
• VAT returns,
• the business plan and financial analysis,
• the implementation schedule,
• documents confirming the right to use the property or the availability of the own contribution.

The list should be prepared on the basis of the call documentation and ticked off as the individual items are compiled.

Consistency of financial and substantive data

While preparing the application, the consistency of data between the different documents should be verified systematically. The total project amount, the value of eligible costs, the amount of funding requested, the own contribution and the funding level must be identical in the application generator, the business plan, the physical and financial schedule and all annexes. Any change in one document requires the others to be updated.

Full completeness test before submission

At least 48 hours before the call closes, a full verification of the completeness of the application should be carried out, including:

• comparing the content of the documentation with the checklist once again,
• verification of electronic signatures,
• checking that the annexes are correct,
• a trial submission of the application in the system.

A time buffer helps avoid the risk associated with technical problems with the IT system, which are particularly frequent in the last hours of a call.

Specific issues relating to electronic signatures

Grant applications are currently submitted exclusively in electronic form, most often via systems such as LSI, SOWA EFS, WOD2021 or generators dedicated to individual institutions. Signing documents requires a qualified electronic signature, a trusted signature or a personal signature from an e-ID card – to the extent permitted by the call rules.

In the case of companies with joint representation, all persons authorised to represent the company must sign the application and the annexes requiring a signature. A power of attorney for representation in the call procedure should be drawn up in a form that complies with the requirements of the given call – in many cases, written form with a notarially certified signature or electronic form with a qualified electronic signature is required.

Detailed information on the rules for submitting applications and the technical requirements is available on the European Funds website, which is the primary source of information on programmes financed from European Union funds.

What to do if you receive a request to remedy deficiencies

Receiving a request to remedy formal deficiencies does not mean that the application has been rejected. The institution specifies the scope of the deficiencies and the deadline for remedying them – usually 7 to 14 days, in accordance with the rules of the given call. Key rules of conduct:

• read the content of the request carefully and make sure you understand every objection raised by the institution,
• the response should cover all the deficiencies indicated – omitting any of them may result in the application being left unexamined,
• the supplement must be submitted in the required format and through the required communication channel, most often via the same IT system in which the application was submitted,
• the deadline is counted from the date of delivery of the request, not from the date it was sent – it is worth verifying the delivery date in the system.

It should be remembered that some deficiencies cannot be remedied. Submitting an application after the deadline, not having the status that entitles you to apply for funding or a mismatch between the subject of the project and the scope of support of the programme result in the application being rejected without the possibility of supplementation.

The most common mistakes made by applicants

Consultants' experience shows that applicants repeat several typical mistakes that can be avoided with proper preparation:

• Starting work too late – comprehensive preparation of the documentation usually takes 4 to 12 weeks, depending on the scale of the project and the programme.
• An out-of-date version of the rules – institutions publish changes while the call is in progress.
• Insufficient analysis of the catalogue of eligible costs – leading to the inclusion in the application of expenditure that cannot be financed from the grant.
• Incorrect interpretation of definitions – terms such as “start of the project”, “incentive effect”, “product innovation” or “undertaking in difficulty” have a precise legal meaning, and misunderstanding them may result in the application being rejected or the loss of entitlement to funding at a later stage.

The role of expert support in the application process

Using grant advisory services can significantly reduce the risk of formal deficiencies. An experienced consultant knows the typical documentation pitfalls of individual programmes, understands the specifics of the IT systems of individual institutions and is able to quickly identify potential shortcomings before the application is submitted. Professional support also covers the stage of any supplements and appeals against a negative assessment.

Applicants can also use the free grant search engine, which makes it possible to quickly identify programmes matching the business profile and the planned investment. This is the first step in avoiding the mistake of applying to the wrong programme.

Are you preparing a grant application and would like to have its completeness checked before submission? Please get in touch.Contact an expert