As a general rule, all project partners have to keep all supporting documents relating to the project for a five-year period (known as a ‘retention period’) from 31 December of the year in which the MA/JS made the last payment to the lead partner.¹ For example, if the MA/JS made the last payment on 12 March 2026, the supporting documents must be retained until 31 December 2031.
¹ REGULATION (EU) 2021/1060, Article 82
Project-related supporting documents are, for example:
Project contracts and declarations, such as the subsidy contract, partnership agreement, partner declarations, etc.
Accounting documents relating to project expenditure and which are required to ensure an adequate audit trail, such as invoices, payment proof, employment contracts, etc.
Documents confirming fulfilment of the conditions for support in the case where the project is implemented via simplified cost options, such as confirmation of employment, reports of hours, etc.
Documents relating to controls and audits, such as control checklists, audit reports, etc.
Procurement documentation, such as terms of reference, selection decisions, service contracts, etc.
Other project-related documents, such as minutes of project partner meetings, important e-mail communication with project partners or the MA/JS, etc.
Partners that receive State aid have different retention periods. Their retention periods depend on the aid measure under which the Programme support was granted:
Partners receiving aid granted under the General Block Exemption Regulation (GBER) have to retain documents for 10 years from the date on which the last aid was granted under the relevant GBER scheme of the Programme.
REGULATION (EU) No 651/2014, Article 12(1)
o Partners receiving aid granted under the de minimis Regulation have to retain documents for a period of 10 fiscal years from the date on which the aid was granted (e.g. from the date when the last party signed the subsidy contract or the addendum to the subsidy contract). The exact starting date is stated in the de minimis award letter issued to the project partners concerned.
COMMISSION REGULATION (EU) No 2023/2831, Article 6(3)
In all cases, this given retention period is interrupted either in case of legal proceedings or by a request from the European Commission. Other possibly longer statutory retention periods, as might be required by national law, remain unaffected.
All partners have to retain the supporting documents together and archive them. They can be kept either in the form of originals or on commonly accepted data carriers. In the latter case, the versions have to conform with the original. The conformity has to be certified. The procedure for certification of conformity must be in line with the provisions set by the national authorities. It has to ensure that the versions held comply with the national legal requirements and can be relied on for audit and control purposes. Where documents are retained electronically, internationally accepted security standards must be met.
